FINAL PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT:
U.S. LAKE ERIE NATURAL GAS RESOURCE DEVELOPMENT
COMMENTS AND RESPONSES
August 1981
DRAFT
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UNITED SfAltS
^ ^ tNVIRONMEMTAL PROTECTION AufcNCY
5 i RFGION V
1
uss;
230 SOUTH DEARBORN ST
CHICAGO. ILLINOIS 60604
PflO^ REPLY TO ATTFNTION ~'V.
V. J? CHICAGO. ILLINOIS 60604
f*< PflO^°
Colonel George P. Johnson
District Engineer
Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14202
RE: 80-049-115
D-C0E-F02001-00
Dear Colonel Johnson:
He have completed our review of the Draft Environmental Impact Statement (EIS)
for the U.S. Lake Erie Natural Gas Resource Development. This Draft EIS
addressed the environmental consequences of natural gas resource development
in the Eastern and Central basins of U.S. Lake Erie. The Draft EIS did not
make any judgement related to individual permit applications or the issuance
or denial of any such permit, but rather addressed natural gas development
in a generic sense.
The EIS describes a Reference Program which defines the proposed activities
and the conditions and permit requirements which will be applied once a formal
application is made. The establishment of a regulatory task force is recommended
to develop the standard lease forms, drilling permit forms, and construction
and operation permit forms, and recommend minimal Federal standards. Based upon
the information provided in the Draft EIS and the conditions, constraints,
mitigation measures, restriction of use in certain areas, method of waste
handling, etc. which will be applied, we do not have any major objections to
the Reference Program. He are concerned, however, about the potential Impacts
that could occur locally from specific facilities, but understand that assessment
of significant localized Impacts through a generic EIS is not practical. Under
the COE's regulations for implementing the National Environmental Policy Act,
an EIS decision must be made for each permit. Considering the scope and the
potential impacts of any gas development activities, we recommend an EIS be
prepared for all future projects until criteria can be substantiated which will
provide adequate environmental protection.
Based upon our review of this Draft EIS, we have rated the project as L0
(Lack of Objection) and classified the EIS as Category 2 (Additional Infor-
mation Necessary). Our detailed comments are attached. The date and classi-
fication of our comments will be published in the Federal Register in accord-
ance with our responsibility to inform the public of our views on other
agency's projects.
1 5 JA: .' J931
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We appreciate the opportunity to review this Draft EIS. If you have any
questions regarding our comments, please contact Mr. William D. Franz at 312/
886-6687 or FTS 886-6687. When the Final EIS is completed and distributed,
please send us four copies.
Sincerely yours,
Ba
Environmental Impact Review Staff
Office of Environmental Review
Attachment
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U.S. ENVIRONMENTAL PROTECTION AGENCY'S COMMENTS OH THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR U.S. LAKE
ERIE NATURAL GAS RESOURCE DEVELOPMENT
The Environmental Impact Statement (EIS) has been written in the absence of a
specific project proposal. The Reference Program contains a set of guidelines
incorporating state-of-the-art technologies and strict operational procedures
designed to minimize possible releases to the environment. While the EIS,
through the Reference Program, attempts Co minimize the environmental impacts,
in a generic sense there will be some adverse impacts which will be contingent
on the particular areas selected for individual facilities. There are 14 lease
areas, and 10 landfall areas in the Central and Eastern Lake Erie basin where
natural gas development is proposed. The specific impacts which could possibly
occur from a particular development cannot be, and have not been, addressed in
this EIS. Depending upon the location of the wells, the flow pipelines, shore-
line facilities, gas production facilities, and waste disposal sites, the
environmental impacts could be significant. Based upon these considerations,
we envision that an EIS would be necessary for any gas development due to the
potential localized primary and secondary impacts of any such project.
Disposal of Drilling and Stimulation Fluids and Other Wastes
The Reference Program requires drilling fluids, stimulation fluids, and residuals
to be collected, stored, and relegated to land disposal sites whenever possible.
The EIS should define the circumstances when collection, storage, and land
disposal will not occur. The type of on-land disposal sites necessary and their
locations must be determined prior to individual natural gas development. Should
land disposal not occur and open water disposal be considered, then the proposal
must be re-evaluated with a view toward defining the fate and effect of dis-
charged materials.
' During the drilling and stimulation processes, there is the potential for the
generation of hazardous wastes. Applicants for gas development should be aware
that materials are considered hazardous if they contain wastes which are defined
by the Hazardous Waste and Consolidated Permit Regulations found in the May 19,
1980 Feaeral Register, book 2 of 3, pages 33063 to 33285. Materials are con-
sidered to be hazardous if they coutain wastes listed in 40 CFR Part 261, Sub-
part D or if they exhibit the characteristics of corrosivity, reactivity,
ignitability, or E.P. toxicity, as defined in the above regulations. The EIS
stated that periodic monitoring would be done to assure that wastes would be
disposed of in a proper manner. If the materials are determined to be, or are
designated, hazardous they will then have to be transported, stored, and disposed
in a manner consistent with the above regulations. We offer our assistance in
determining the applicability of the Hazardous Waste and Consolidated Permit
Regulations to natural gas drilling in Lake Erie.
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The EIS mentions (Section 1.122, page 1-85) that there are a limited number of
Resource Conservation and Recovery Act landfills in the Reference Program Study
region. We would like to elaborate upon this point by stating that the only
site in the State of Ohio presently classified as suitable for such disposal
is located in Cincinnati, Ohio.
/ The EIS also states that solid sludges produced at on-shore treatment/disposal
facilities are likely to be hazardous and should go to a Resource Conservation
and Recovery Act permitted landfill. An alternative discussed in the EIS
suggests the use of on-land dredged spoil disposal sites, instead of Resource
Conservation and Recovery Act permitted hazardous waste management facilities.
These sites would not be acceptable for the disposal of hazardous wastes.
Impacts Upon Water Quality Due to Accidents
Table 4-5 categorizes the impacts of all accidents. Accidents can vary from
those occurlng during construction activities, e.g., drilling rigs capsizing,
to those occurlng during operations, e. g. a flowline rupturing from an anchor
dragging along the bottom. The categorization of the impacts in Table 4-5
indicates these impacts will be moderate and localized. The substantiation for
this determination should be Included in the Final EIS. The fate and effects
of pollutants should be assessed to determine if the impacts are moderate and
localized.
Table 1-35 and Appendix paragraph C.008 describe flowline rupture as a moderate-
frequency accident. (Although paragraph 4,.067 states that the possibility of
rupture from dragging anchors appears minimal). It appears that the consequences
of such an accident (as described in Table 1-35 and appendix paragraph C.008)
could be severe, and the severity and probability appears to be greater for this
type of accident then for most others. The. applicant should be required to
develop contingencies to prevent such accidents from occurlng and to minimize
the impacts, if they do occur.
Worst-case assumptions in paragraph C.008 state that the pressure drop after a
flowline rupture may go undetected for up to 24 hours. Is there any way in
which state-of-the-art flowline monitoring can ensure earlier detection and
action? It is also assumed in this paragraph that if the safety valve fails to
actuate, it may take up to three days to stop the flow of gas by repairing the
break. Will there be a way to manually actuate the safety valve or other valves
to stop the flow of gas immediately?
Air Quality
On-land processing facilities will undoubtedly have an impact upon air quality.
The entire Ohio Lake Erie basin is nonattainment for ozone and portions of Erie,
Lorain, Cuyhoga and Lake Counties are nonattainment for sulfur oxides. In order
to construct processing facilities in these areas, emission offsets may be
necessary in order to comply with the State Implementation Plan. The state new
source permitting authority should be contacted in regard to the need to apply
for emission offsets.
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Additional Comments
It should be noted that where a discharge from one state may affect the
water quality of another state, our Agency must notify the affected state.
This state then has the opportunity to comment on the 401 certification.
One of the goals of the Reference Program is to establish a Regulatory Task
Force. This Regulatory Task Force would be composed of Federal agencies and
the three states involved, and would be responsible for the development of
the standard lease form, drilling permit forms, and construction and
operation permit forms. In addition, a minimum set of standards to guide
offshore Lake Erie natural gas development activities would be developed by
the Regulatory Task Force. The EIS should describe the public involvement
in the Regulatory Task Force process. While.it may not be advantageous to
have members of the public participate in the Task Force meeting, the public
should have the opportunity to review and comment on the Task Force's
recommendations.
The EIS indicated there was a potential for additional dredging at several
harbors on Lake Erie. The Final EIS should provide information on which har-
bors may have to be dredged, an estimation of the quantity of material to be
dredged, and the pollutional classification of this material.
The following procedural point is noted: the EIS indicates (1.069) that
EPA reviews of Section 10 and 404 permit applications will be carried out
by the Office of Federal Activities. This appears to be an incorrect ref-
erence to the Office of Environmental Review, Headquarters; but more appro-
priately, the EIS should indicate that these permit reviews will be con-
ducted by the regional staff responsible for 404 program administration.
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DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION APMINISTRATION
November 21, 1980
Col. George P. Johnson
District Engineer
Regulatory Functions Branch
Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Dear Colonel Johnson:
The FAA Eastern Region has no comment on the Draft Programatlc
Environmental Statement entitled, "U.S. Lake Erie Natural Gas
^Resource Development.
Sincerely,
1AJU1S AUtiXUtt
Noise Abatement and Environmental Officer
EASTERN REGION
rtDCRAL BUILOINS
JOHN F. KENNEDY INTERNATIONAL AIRPORT
JAMAICA. NEW YORK M490
/
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^Se*\ United Slates
!>U^Jp Department of
Agriculture
December 9, 1980
Soil 200 North High Street
Conservation Room 522
Service Columbus. Ohio 43215
Colonel George P. Johnson
Attention: Regulatory Functions Branch
District Engineer
U.S. Army Engineer District, Buffalo
1776 Niagara Street
Buffalo, New York 14207
Dear Colonel Johnson:
SCSO-1
The Draft Programmatic Environmental Impact Statement for
U.S. Lake Erie Natural Gas Resource Development was sent to
the USDA Soil Conservation Service, State Conservationist,
Columbus, Ohio, for review and comment.
We have reviewed the Draft Statement and have no comments to
offer. We appreciate the opportunity to review and comment
on this gas resource development.
Sincerely,
CP.
Robert R. Shaw U
State Conservationist
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*»*¦**
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
Q£C 1 - 1980
Mr. George P. Johnson, Colonel
Corps of Engineers
District Engineer
Department of the Army
Buffalo District
ATTN: Regulatory Functions Branch
1776 Niagara Street
Buffalo» New York 14207
Dear Mr. Johnson:
This is in response to your request for comments on the Draft Programmatic
Environmental Impact Statement entitled "U.S. Lake Erie Natural Gas Resource
Development."
'we have reviewed the impact statement and determined that the proposed action
has no significant radiological health and safety impact, nor will it adversely
affect any activities subject to regulation by the Nuclear Regulatory Commission.
However, we would like to be informed and consulted before any final decision
is made to construct any gas pipeline, drilling of production hole and
exploratory drilling within five miles of the "Perry Nuclear Power Plant"
xlocated on Lake Erie in Lake County, Ohio.
Thank you for providing us with the opportunity to review this draft of the
Programmatic Environmental Impact Statement.
Sincerely
Daniel R. Muller, Assistant Director
for Environmental Technology
Division bf Engineering
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Department of housing and urban development
AREA OFFICE
107 DELAWARE AVE.. STATUER BLDG.. MEZZANINE
BUFFALO. NEW YORK 14202
December 12, 1980
REGION II
36 Federal Plaza
New York, New York 10007
IN RCPUT REFER TOs
2.1SS
District Eng i neer
U.S. Army Engineer District, Buffalo
1776 Niagara Street
Buffalo, New York 14207
Attention
Subjec t:
Dea r Sir:
Regulatory Functions Branch
Draft Programmatic Environmental Impact Statement
U.S. Lake Erie Natural Gas Resource Development
Thank you for the opportunity to review subject document.
P
HUD-1 We share your concern for disposal of solid and liquid
wastes that might be hazardous. Because conventional
landfill sites and Resource Conservation and Recovery
Act approved landfills are limited, our specific concern
is that new disposal sites, not be located in proximity
to HUD housing projects,(ex Isting or proposed).
Noise levels from continual compressor operation should
be in accord with HUD Noise Guidelines if in proximity
^to HUD projects.
We have no other comments at this time but desire to re-
main on the mailing list as further environmental analysis
of this major proposal takes place.
Sincerely,
James F. Andet
Area Manager
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- o* "<
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION ONE
New York Division Office
Leo O'Brien Federal Building
Clinton Avenue and North Pearl Street
Albany, New York 12207
December 17,
IN REPLV REFER TO:
HP-NY
Col. George P. Johnson, District Engineer
Corps of Engineers
Department of the Amy
1776 Niagara Street
Buffalo, New York 142^7
Attention: Regulatory Functions Branch
Dear Col. Johnson:
FHWA-1
A copy of your Draft Programmatic Environmental Impact Statement entitled
"U.S. Lake Erie Natural Gas Resource Development" was sent to the Regional
Administrator for the Federal Highway Administration (FIIWA) for review and
comment. The DEIS was forwarded to the New York Division Office for action.
~
Please be advised that we have no comment on this document, although we
appreciate the opportunity to review it. In accordance with the request in
your public notice we are returning the DEIS unmarked for your subsequent
^se.
Sincerely yours,
Victor E. Taylor
' Division Administrator
Enclosure
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DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
Centers for Disease Control
Atlanta, Georgia 30333
(404) 262-6649
January 5, 1981
IHS-1
IHS-2
fflS-3
Colonel George P. Johnson
District Engineer
U.S. Army Corps of Engineers District, Buffalo
1776 Niagara Street
Buffalo, New York 14207
Attention: Regulatory Functions Branch
Dear Colonel Johnson:
We have reviewed the Draft Programmatic Environmental Impact Statement (EIS)
for the U.S. Lake Erie Natural Gas Resource Development. We are responding
on behalf of the U.S. Public Health Service and are offering the following
comments for your consideration in preparing the final document.
We understand that the purpose of the subject DEIS is to describe the environ-
mental effects associated with the Reference Program and to provide guidance
to the Corps and the U.S. Environmental Protection Agency in determining "...
whether U.S. Lake Erie natural gas resource development can be: (1) approved
as defined in the Reference Program, (2) approved as defined.with qualifica-
tions, or (3) disapproved as unacceptable in principle."
In general, we have no major objections to any of the Reference Program
guidelines that are designed to safeguard the environment. However, we believe
the EIS should elaborate more on the health and safety Impacts of the Reference
Program. For example, Section 4.129 indicates that accidental gaseous releases
from an explosion and/or fire at a gas treatment plant or from a pipeline
rupture "...can have a potentially deleterious effect on the general public."
, The potential public health effects that might result from a worst-case
' accident of this type should be detailed. In addition, the ability of local
building codes, zoning and set-back regulations in the region to satisfactorily
protect the general public (i.e., residents) from any accidents associated with
gas flowlines and natural gas development facilities should be discussed.
' The technical basis for prohibiting drilling and pipeline construction within
.5 mile of a potable water intake in order to protect water quality and public
health should be discussed. What research exists to justify the .5 mile
designation?
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Page 2 - Colonel George P. Johnson
He appreciate the opportunity to review this EIS. Pleaae send us one copy
of the final document when It becomes available.
Sincerely yours,
n -4 3
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Bureau of State Services
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ER-80/1360
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
JAN
7 1981
Colonel George P. Johnson
District Engineer, Buffalo
Corps of Engineers
Department of the Army
1776 Niagara Street
Buffalo, New York 14207
Dear Colonel Johnson:
We have reviewed the draft programmatic environmental statement for
U.S. Lake Erie Natural Gas Resource Development, sent to us on
November 3, 1980. Based upon the information provided, the U.S.
Fish and Wildlife Service does not anticipate objecting to the
issuance of Department of the Army permits for offshore natural gas
resource developments. However, we suggest that consultation with
the Service be initiated early in the planning stages if it appears
that Department of the Army permits will be required for any of the
onshore facilities.
Most of the onshore Federal land in the area is under the jurisdiction
of the Corps of Engineers and the Forest Service. As you are aware,
mineral leasing for these agencies is managed by our Bureau of Land
Management (BLM). A review of BLM records indicates that no signifi-
cant Federally leased mineral extraction activities are occuring in
the involved area. Consequently, no impacts, direct or indirect, to
minerals leasing would occur. However, the current lease.listing for
oil and gas (attached) shows a substantial amount of oil and gas
exploration in areas that are potential sites for the onshore portion
of the Lake Erie Natural Gas Resource Development. Therefore, a
comparison between the Lake Erie project and BLM's programmatic
stipulations for oil and gas leases was performed, revealing a
difference in road/pipeline right-of-way widths for onland access to
well sites. BLM allows only a 20-foot width to minimize forest and
wildlife impact. Conversely, the Lake Erie project suggests an over-
all right-of-way of 35-50 feet, including a 16-2U foot width for
roads. A possible compromise is to allow the 16-2"+ foot width for
road surface but reduce the overall right-of-way to 30 feet. This
would minimize impacts but still allow heavy equipment access for
pipeline construction and wellsite drilling. The other stipulations
for road construction are comparable and thereby compatible.
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Doi-s'one other significant contradiction in stipulations concerns burning
refuse onsite. BLM stipulates that incineration is incompatible with
overall waste disposal procedures. The usual method of waste disposal
(sanitary and solid waste) is by trucking to authorized landfills
and/or treatment facilities. The Lake Erie project would allow the
incineration of some onsite refuse such as cement bags, paper product
casings, etc. To unify procedures, an overall no-burn policy should
be maintained. No-burn procedures would also reduce the risk, how-
ever slight, of onsite gas leak combustion.
Cultural Resources
DO 1-4(The Corps of Engineers should maintain close consultation with the
State Historic Preservation Officers in the affected States while the
cultural resource study is being conducted. The State Historic
Preservation Officers (SHPO's) should be afforded an opportunity to
comment on the adequacy of the study and should be consulted on the
development of any measures proposed to mitigate impacts to cultural
resources. Results of this consultation should be included in the
environmental statement along with results of the cultural resource
study and any possible impacts and proposed mitigation measures.
The SHPO's for New York, Pennsylvania, and Ohio are Mr. Orin Lehman,
Commissioner, Parks and Recreation, Agency Building #1, Empire State
Plaza, Albany, New York 12238; Mr. Edward Weintraub, Executive
Director, Historical Museum Commission, P.O. Box 1026, Harrisburg,
Pennsylvania 17120; and Mr. Delias Harder, The Ohio Historical Society,
^Interstate 71 at 17th Avenue, Columbus, Ohio 4 3211.
Recreation Resources
''The Statewide Comprehensive Outdoor Recreation Plans for New York,
Pennsylvania and Ohio are cited in the reference section of Chapter
t, but are not discussed in conjunction with the recreational impact
of this project. The Corps of Engineers should contact the responsi-
ble State officials to ascertain how activities such as recreational
fishing, boating and shoreline resources would be affected. The
State Liaison Officers for New York, Pennsylvania and Ohio are
responsible for the formulation of the comprehensive plans and are,
respectively, Mr. Orin Lehman, who is also the SHPO; Mr. Clifford
Jones, Secretary of Environmental Resources, P.O. Box 1467,
Harrisburg, Pennsylvania 17.120; and Mr. Robert W. Teater, Director,
Department of Natural Resources, Fountain Square, Columbus, Ohio
43224.
Accidents
DO 1-5
1!
D0i-6[We believe additional discussion regarding accidents involving oil and
hazardous substances is needed. The potential environmental damages
resulting from the hypothetical worst cases for exploratory well
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blowouts- on page C-4 and for capsized jack-up rigs on page C-6
should be discussed. The document states that oil from blowouts and
diesel fuel from capsized rigs could be windblown to shore. If so,
,shoreline resources, including recreation, might be severely affected.
~
Under Accident Contingency Plans in Chapter 1, plans and agencies
designated to deal with oil and hazardous substances spills are
described. However, no information is provided regarding the
technical capacity of these agencies to adequately deploy the
necessary clean-up measures before contamination affects the shore.
The environmental statement should discuss the emergency clean-up
measures which would be used for each of the above-discussed worst
cases. The likelihood of success of such measures under a variety
of possible weather conditions and accident locations should then
be discussed. The potential short-term and long-term effects of
such spills on aquatic and coastal resources should be discussed in
appropriate sections.
\
Wildlife Resources
t
More specific information regarding probable impacts on aquatic and
terrestrial resources should be presented; this can be drawn from
OCS oil and gas operations as well as past Canadian operations in
Lake Erie. Since Canada has 25 years of experience in developing
and producing Lake Erie natural gas, we suggest that the environ-
mental statement contain more information regarding the environmental
problems and successes they encountered. This information should
include, but not be limited to, the following: aquatic impacts,
impacts of associated onland facilities (pipelines, spoil disposal
sites, injection wells, storage facilities, etc.), mitigation
measures, accidental spills, and environmental monitoring studies
,or systems.
'Operations described in the Onland Alternative Program may
significantly impact aquatic populations in streams within the 27-
county study area. The environmental statement fails to properly
consider the impacts of chronic and acute oil and salt water
pollution that characterize current oil and gas production opera-
tions in the Onland Alternative study area.
t
DOl-10 The environmental statement ignores the improvements in water quality
that have occurred in Lake Erie in recent years. Many of the refer-
ences utilized as data to analyze impacts were written before the
efforts to restore water quality in Lake Erie began to show success.
We appreciate the opportunity to review and comment on this
statement.
Sincerely
mtus\ |
/ tpuciax Assistant to
SECRETARY
Enclosures
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SPECIFIC COMMENTS
Onland Alternative Program - page 2-24, paragraph 2.091. This
paragraph states that site-specific environmental descriptions are
not available for either program. We suggest using the Canadian
offshore gas developments to estimate the probable environmental
effects of U.S. offshore developments. The Onland Alternative
Program is proposed for an area where oil and natural gas are
currently being produced.. There are significant environmental
problems associated with some of this ongoing production that
should ba addressed. Chronic salt water and oil pollution results
from both active and abandoned wells and pipelines. Acute oil
spills can result from pipeline or storage tank ruptures. Impacts
of and measures to control chronic and acute oil and salt water
pollution should be addressed in the final environmental statement.
Terrestrial Ecology - page 2-25, Table 2-6. Many sections of the
Onland Alternative Study area have large tracts of maturing
forests. The environmental statement should discuss the advantages
to wildlife of scattered 3-acre clearings such as are proposed for
the Onland Program. Proper revegetation of these sites and the
access roads can significantly benefit wildlife.
Endangered Species - page 2-25, Table 2-6. See comments, page
•+-32, paragraph 4.090.
Water Quality - page 3-9, paragraph 3.028. The second paragraph
of page 3-9 reports on Lake Erie's extreme eutrophication in the
early 1970's, the water quality agreements between the U.S. and
Canada signed in 1972 and 1978, and the initiation of massive
remedial action. The report fails to take into consideration the
fact that Lake Erie's water quality has improved greatly. Signi-
ficant increases in sport fish populations have been noted in
recent years.
Sport Fishery - page 3-15, paragraph 3.053. The dollar value of
the sport fishery should be converted to current values rather
than averaged back to 1965.
Sport Fishery - page 3-15, paragraph 3.051. This section should
bel revised to discuss the importance of walleye and coho and
Chinook salmon to the sport fishery. Recent State/Federal efforts
to restore lake trout to Lake Erie should be presented.
Commercial Fishery, page 3-15, paragraph 3.055. This section
should be revised to include bait fish. The 1973 reference will
not reflect the vast improvement in water quality and resulting
changes in species composition.
Commercial Fishery - page 3-16, paragraph 3.057. The statement
"In Pennsylvania it is doubtful that commercial fishing still takes
place" is in error. There are numerous commercial fishermen
operating out of Erie, Pennsylvania.
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-19
Wetlands - page 3-24, paragraph 3.079. The statement that
Pennsylvania has no overall wetland policy at present " may not
be totally accurate. Amendments to the Dam Safety and Encroachment
Act (32 P.S. Sect. 693.1-693.2) and regulations implemented on
September 27, 1980 (25 PA Code CH 105), now provide comprehensive
protection to wetlands.
Wildlife - page 3-25, paragraph 3.084. The statement "Raptors
continue to decline because of reproductive failure due to
pesticides should be documented by recent literature.
^Wildlife - page 3-25, paragraph 3.085. The statement "Only the open
water of Lake Erie and Erie Bay are used by waterfowl, both during
and over winter" is' erroneous. Two excellent wetlands, Conneaut
Marsh and Pymatuning Swamp (mentioned in paragraph 3.079), as well
as numerous other wetlands and waterways in the Erie region, are
heavily used by waterfowl.
'The statement "Inland streams support high populations of muskrat
and beaver" is somewhat misleading. Although some streams in this
area provide excellent muskrat habitat, the wetlands mentioned
above are among the most productive muskrat habitat in Pennsylvania.
Endangered Species - page 4-32, paragraph 4.090. This paragraph
needs clarification. The difference between significant adverse
effects of both programs on species or populations of species that
are endangered, rare or threatened and adverse direct impacts on
^an individual animal or plant should be explained.
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Federal Energy Regulatory Commission
WASHINGTON 20426
IN REPLY REFER TO.
January 8, 1981
Colonel George P. Johnson
District Engineer
U. S. Department of the Army
Corps of.Engineers, Buffalo
District
Buffalo, New York 14207
Dear Colonel Johnson:
This letter and enclosure provide comments made by the Federa
Energy Regulatory Commission staff on the "Draft Programmatic
Environmental Impact Statement: U. S. Lake Erie Natural Gas Re-
source Department." While the DEIS is lengthy and detailed, it
appears to be sufficiently definitive in describing impacts and
'offering solutions to the problems presented. We believe that
certain portions of the DEIS could have been improved, however, by
coordination with the PERC. Additionally, we would direct your
attention to the fact that the Commission has placed considerable
emphasis upon regulatory actions that would correct imbalances
^between natural gas supply and demand.
The enclosed comments are directed toward those aspects of
the DEIS that relate to the natural gas responsiblities of the
Commisison.
We are appreciative of the opportunity to review and comment
upon the DEIS.
Sincerely
yack M. Heinemann
'Advisor on Environmental Quality
Coordinator, Coastal Zone Affairs
Enclosure
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January 8, 1981
FEDERAL ENERGY REGULATORY COMMISSION
Staff Comments on the Programmatic Draft
Environmental Ipact Statement (DEIS)
for U.S. Lake Erie Natural Gas Resource Development
Prepared by
U. S. Army Corps of Engineers and the U. S. Environmental
Protection Agency
Page 1-4. Natural Gas Supply and Demand
' A FERC survey of the nation's major interstate natural gas
pipeline companies and their customers indicates that curtailment
of natural gas service is not expected to result in any signifi-
cant industrial or commercial dislocation or shutdown during the
present winter heating season. The projection of an adequate gas
supply for priority needs such as home heating, as well as for
normal industrial and commercial operations, is contained in a
recent FERC staff report, "Impact of 1980-81 Winter Gas Supply
for 28 Pipeline Companies." (Copies of this report can be obtained
through the FERC's Division of Public Information (telephone (202)
357-8055).) This detailed analysis by the Commission's Office of
Pipeline and Producer Regulation reveals that, even if this winter
is somewhat colder than normal, projected deliverability from all
gas supply sources — including storage withdrawal, emergency gas,
and intrastate pipeline companies — will be adequate to meet
demand. The 28 companies surveyed, representing 99 percent of the
gas transported by interstate pipelines, projected available
market supplies from November 1980 through March 1981 will total
6,286 billion cubic feet (Bcf), compared to 6,300 Bcf delivered
last winter.
Y Numerous factors indicate that natural gas supplies will im-
prove, at least for the short term. Reduced demand for natural
gas resulting from conservation efforts, a slow-dovn of the national
economy, and price competition from alternative energy fuels such
as oil and coal are cited as the reasons for the slight decrease of
anticipated deliveries for this winter. However, the long-term
outlook for natural gas supplies is less clear. No realistic
forecast of natural gas availability can be projected beyond the
next few years until the effect of the Natural Gas Policy Act of
1978 (NGPA) on production can be better evaluated.
-------
"omments/20
2 -
ERC-4
Page 2-1. Natural Gas Policy Act
" The DEIS discusses the NGPA in several sections, but it does
not clearly delineate the FERC's role in administering the NGPA
or its responsibility in interstate natural gas regulation. The
final statement should include the following information:
The FERC is primarily responsible for administering
and enforcing compliance with the NGPA (92 Stat.
3350). The NGPA establishes a series of statutory
maximum lawful prices for various categories of
natural gas, including gas destined for both the
intrastate anc1. interstate markets. Under the NGPA,
if the gas involved is located on lands subject to
state jurisdiction, determinations of eligibility
are made by the appropriate state agency regulating
gas production; if the gas is located on lands
under Federal domain, a Federal agency makes the
determination. Determinations of NGPA eligibility
are subject to FERC review. In addition, all inter-
state natural gas is subject to FERC jurisdiction.
The Natural Gas Act and the National Environmental
Policy Act grant authority or require that the FERC
investigate the environmental effects of a proposed
gas transportation project, as well as the potential
gas reserves, the need for this gas, and the
availability of capital to develop this resource.
FERC-5
Page 2-4. Alternative Supplies of Natural Gas
' The discussion of alternatives to the proposed action should
note that even if the most optimistic estimate of natural gas
reserves proves correct, such supplies would do very little to
offset any future imbalance between natural gas supply and demand.
However, realizing th?.t a solution to the energy problem w.ill be
achieved only if all practicable energy supply options are
pursued, we suggest that the FEIS stress the national need for
>all forms of energy resource development.
-------
"omments/21
United States -
uLgJl) Department of
\sBy Agriculture
Soil
Conservation
Service
U. S. Courthouse and Federal Building
100 South Clinton Street, Room 771
Syracuse, New York 13260
SCSN-1
January 9, 1981
Colonel George P. Johnson
District Engineer .
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Dear Colonel Johnson:
The National Office of the Soil Conservation Service has forwarded the
"Draft Programmatic Environmental Impact Statement for U. S, Lake Erie
Natural Gas Resource Development" prepared by the U. S. Army Corps of
Engineers and the U. S. Environmental Protection Agency (transmittal
dated November 10, 1980) to this office for review and comment.
We have reviewed this statement from the standpoint of SCS expertise,
interest and responsibilities.
t
The statement does recognize, as best possible, the nonspecific related im-
pacts of On-Land Alternative Programs as they relate to agriculture and
prime farmlands. General mitigating measures such as salvage and reuse
of topsoils and erosion control during drilling and pipeline installation
activities are addressed.
We appreciate the opportunity to review and comment on this statement.
Sincerely,
Paxil A. Dodd
State Conservationist
cc: Office of Federal Activities, EPA, New York, New York
Norman A. Berg, Chief, SCS, Washington, D. C.
Homer R. Hilner, Director, NETSC, SCS, Broomall, Pa.
6
The So3 Conservation Serviee
is an agency of the
Department or Agriculture
SCS-AS-1
10-79
-------
Comments/22
rv\
UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary far Policy
Washington. D.C. 20230
UAN 1 3 1981
Colonel George P. Johnson
District Engineer
Buffalo District, Corps of Engineers
Department of the Army
1776 Niagara Street
Buffalo, New York 14207
Attention: Regulatory Functions Branch
Dear Colonel Johnson:
This is in reference to your draft programmatic environmental impact
statement entitled, "U.S. Lake Erie Natural Gas Resource Development."
The enclosed comments from the National Oceanic and Atmospheric
Administration (NOAA) are forwarded for your consideration.
Thank you for giving us an opportunity to provide these comments, which
we hope will be of assistance to you. We would appreciate receiving eight
(8) copies of the final statement.
Sincerely,
Robert T. Miki
Deputy Assistant Secretary for
Regulatory Policy (Acting)
Enclosure Memo from: Eugene J. Aubert
Environmental Research Laboratories
NOAA
-------
omments/23
U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
ENVIRONMENTAL RESEARCH LABORATORIES
Great Lakes Environmental Research Laboratory
2300 Washtenaw Avenue
Ann Arbor, MI. 48104
December 31, 1980
TO:
FROM:
SUBJECT:
Joyce Wood PE^ECj /,
Eugene J. Aubert^u)/RF24
DEIS 8011.08 - D. S. Lake Erie Natural Gas
Resource Development in Offshore Waters of
New York, Pennsylvania and Ohio
The referenced draft environmental impact statement (DEIS) has been
reviewed and comments are submitted for your consideration. The subject
matter, because of its sensitivity, warrants a comprehensive analysis
and this was accomplished in a broad spectrum of natural, cultural and
socio-economic Impacts.
D0C-1 Chapter one is an extremely detailed description of a scenario for
developing gas reserves in portions of Lake Erie. It develops gas reserve
estimates and locations, detailed engineering applications and an economic
analysis of the projected period of gas production. This discussion is
interesting and educational but one wonders if the conduct of such a study
should be in the private sector.
DOC-2
DOC-3
DOC-4
r
The chapter consistently ignores the presence of gas development with
a 30-year history from the same reservoirs in the same lake. The
tabulations of potential hazards are extremely thorough as are the reviews -
of institutional controls and gaps. However, these could all have been
listed from existing information without the gas development scenario.
Chapter 2 discusses alternatives to development of gas reserves in Lake
Erie. The discussion centers on economic viability of the various
alternatives including Alaskan and foreign gas as compared to the scenario
developed in Chapter 1. This again is an interesting analysis of the
potential for natural gas development in Lake Erie but its relation to the
environmental impact of developing reserves under the lake is remote. As
pointed out in the introduction, economics and political implications are
outside the scope of this DEIS.
Chapter 3, Environmental setting, describes the natural, cultural and
socio-economic characteristics of the shoreline counties in detail. Most
10TH ANNIVERSARY 1970-1980
National Oceanic and Atmospheric Administration
A young agency with a historic
tradition of service to the Nation
-------
"omments/24
2
of this material is irrelevant to development of the DEIS. For example,
the projected demand for natural gas relates to the need for development
of this resource. The document repeatedly states that development of gas
is not being considered in the study but then expends considerable effort
in assessing the need for development.
The rationale for development of an' on-land alternative program is not
obvious. Natural.gas has been historically produced in the region. If
reserves are available and a demand exists, these reserves will be exploited
and the potential for and cost of development will be less than that in Lake
Erie.
Chapter 4 is the focus of the DEIS in that the range of environmental
impacts is addressed. As in other sections of the document, the summary of
environmental impacts at the end of the chapter deals more with mitigation
than with impacts even to the point of prescribing how the drilling platforms
should be painted. Appendix B describes vessel and rig characteristics.
The impression imparted is that this is a plan for development rather than
an environmental Impact assessment.
Although disclaimers are common, the document appears to be a plan
(Reference Plan) for development of gas reserves underlying Lake Erie;
further, the presumption is made that the entire lake area will be developed
in one comprehensive program. In reality the development, if it is ever
permitted, would probably be in stages or within a sequence of geographic
areas depending on local demands and would be undertaken by various
independent interests.
The report is extremely thorough in that all conceivable environmental
impacts are addressed including natural, cultural, social, and economic
aspects. If the background and impacts on these aspects were extracted they
would constitute an environmental impact statement. All of the excellent
background material and scenarios for developing the natural gas resource
then could be included in a report on the feasibility of developing the
^natural gas resource in Lake Erie.
*
This DEIS should be especially good because the years of drilling and
production experience in the northern part of the same lake can provide a
wealth of data on every natural aspect. For some reason the report ignores
the Canadian experience. Is their information proprietary? The excellent
Canadian reports pertinent to other facets of the document have been
referenced extensively. This experience can be readily quantified and,
combined with the impact assessment in Chapter A, would be preferable to
the postulations incorporated in the Reference Program
present a plan for development of a resource but rather should assess
^ environmental consequences of such development.
The DEIS should not
the
DOC-10
r 4
^IX, s.
A few specific-comments are Included below for your further consideration.
018 No evidence here that hydrocarbon releases are small and localized.
-------
"omments/25
DOC-11
DOC-12
S .020
D0C-13
[*'
^XI,
^XI, s.
Statistical background for such occurrences must be readily
available. Quantify here rather than postulate.
S.025 History on Canadian side of lake can be used here rather than
guesses.
D0C-14b£
DOC-15
DOC-16
DOC-17
If toxic elements are exposed and transported, the effect will
not be temporary if they can then enter the food chain.
D0C-14a 1-8, Onland program rationale is incongruous. Exploration and
1.024 production obviously is cheaper and potentially less harmful to
the environment. If a demand exists then on-land development
should take place. Your deduction says there is no demand for
production anywhere in the region at this time.
Why do all projections stop at the waters edge in figures?
Why make educated guesses when producing fields are directly
adjacent? Not clear why the Canadian experience is not used.
It is not available?
No demand is presumed here. Do you presume maximum development
rate? Political-social factors must be considered in such
postulations.
Reason for no emperical data is not clear. An identical program
has been underway in the north portion of the same lake for 30
years. Why can you not extract from the Canadian experiences?
No hypolimnion or anoxic zone in western basin.
'4-1, Rationale for discussing alternatives to development of reserves
4.001 in Lake Erie is not clear. The judgment is being made as to the
relative significance which relates to need. Again, the document
is supposedly addressing the potential environmental impact of
gas production but digresses into an evaluation of the net benefits
• of gas production.
Question about the possibility of a need for engineering
information when filing for a permit is not clear. The law
presently requires this information. Would conceptual approval
of a plan eliminate the requirement?
Disposal of cuttings from on-land program is not addressed.
4-2 Problems associated with disposal should not be different from
lake or land if both are being disposed of on land.
DOC-22 4-13, Another impact of resuspension is to make contained compounds
available to the biota near and at the interface and reintroduce
them into the food chain. This could be a potentially serious
problem.
f 1-23,
1.043
( 1-53,
1.090
[1-103,
1.142
r3-i
U<
DOC-18 [ 3-11,
.041
D0C-19
DOC-20
DOC-21
(
4-3,
Table
4-13,
4.021,
4-20,
4.047,
4-67,
4.197
-------
Comments/26
4
DOC-23
DOC-24
DOC-25
i
4-13, "Localized Areas" Is something of a misnomer. Hydrocarbons
4.023 floating on the surface could reach a shore. The localized
area than would be a reach that would be significant to
riparian interests. Impact of oil is not addressed in
Table 4-5.
~
4-17, Last sentence is not accurate. The benthic community is in
4.034 contact with sediments to a minimal depth that is less than
^ the potentially disturbed depth.
s
4-23, Water quality at beaches could be affected. Earlier
4.059 conclusions in Water Quality Section were that restrictions
on drilling locations are such that inshore zones would be
unaffected. Conclusions should be consistent.
-------
"omments/27
Department of Energy
Washington, D.C. 20585
34/' ? t
- -¦ £2/
Colonel George P. Johnson, C.E.
District Engineer
Buffalo District, Corps of Engineers
1776 Niagra Street
Buffalo, New York 14207
Dear Colonel Johnson:
Your letter of November 3, 1980, which forwarded a copy of
your draft programmatic environmental impact statement,
"U.S. Lake Erie Natural Gas Resource Development" is acknow-
ledged^ The Department of Energy's "technical team" repre-
sentatives, Len Vickers and Bob Kahl, who are assigned to
our Office of Oil and Natural Gas have prepared the enclosed
comments for your study group's consideration.
It should be noted that we greatly appreciate your continued
involvement and leadership in this project. The draft EIS
is an excellent point of departure for further consideration
of a matter of vital interest and support for this office
and the Department. The Technical team members will continue
to be available for consultation and assistance.
Office of Oil and Natural Gas Office of Oil and Natural
Sincerely,
Robert Kahl
L. A. Vickers
Resource Applications
Resource Applications
Enclosure
-------
'omments/28
Comments of Department of Energy Technical Team Representatives,
U.S. Lake Erie Natural Gas Resource Development.
General Comment
This "Draft Programmatic Environmental impact Statement"
write-up is extremely well written, thoroughly researched
and professionally presented. The Environmental Protection
Agency, the Buffalo District Corps of Engineers and the
Argonne Laboratories personnel involved, merit special and
individual "credits" for a tough job, well done.
As a point of departure for later site-specific EIS consi-
derations and requested permitting, this document should
prove to be a useful, responsive and time-saving tool.
Specific Comments
Region V (Chicago) Representative
"Looks like a good job; I can't find much wrong
with it."
"This meets all of the requirements of the clean
air act and the water pollution act."
"Argonne Laboratories is proud of this job and are
glad they did it."
"Ohio's State Energy Office now has a prepared
list of recommended drilling sites - they are more
willing than ever to make a start."
Chicago Operations Office, DOE
"We now have and foresee no objections to proposed
(exploratory drilling) actions in Lake Erie. We
will have to wait for a site specific permit
request for further data. We can't find fault
with this (Draft EIS) effort."
Office of Oil and Natural Gas; Resource Applications,
doe
"National needs for increased natural gas
production in Northeast Quadrant can be amplified/updated."
" Priority national goal to reduce 1980's 75
million dollar imports of foreign oil and resulting
adverse USA balance of payments should be featured."
1 |^5.
"[
004
-------
Comments/29
5.005 "Lake Erie and northeast industrial area needs for
dependable, affordable supply of clean burning
fossil fuels can be quantified and shown to be
vital for arresting decline trend in industrial
outputs."
"South shore of Lake Erie is within 100 miles of a
major interstate pipeline which serves New York
State and New England markets. This can/will be
used to market gas production in excess of local
industrial, commercial and residential demand(s)."
5.011 "The creation of one office (per state) to manage
program is strongly supported. Efforts to imple-
ment a "one-stop" management are appropriate."
1.015 "Post NGPA of 1978 and expected (decontrolled)
increased gas prices are not predicted to alter or
reduce incentives for Lake Erie gas development.
In fact, producers of "local: gas will have more
incentives and advantages than ever - higher
market prices and the reduced/eliminated gas
transmission/transportation costs."
2.016 See notation from 1.015
2.044 Summaries - DOE strongly supports these conclusions
2.045 in 2.044, 2.045, 2.046, 2.056, 2.061, 2.063,
2.046 table 2-7.
2.056
2.061
2.063
2.099,
Table 2-7
-------
Comments/30
Comments on Draft Environmental Impact Statement
Covering U.S. Lake Erie Natural Gas Resource Development
General
A very thorough and comprehensive report supporting
an exploratory and development program involved in the
production of offshore Lake Erie Natural Gas.
Program Status
Awaiting task force establishment. Such task force to
represent the three states involved and appropriate
Federal agencies with the goal to expedite necessary
regulatory prerequisites associated with all related
activities.
Awaiting site-specific Environmental Impact Statement.
I asked someone in technology impacts (part of Environ-
ment) to also look at the document. The EIS looks like
a good document in terms of treatment of energy implications.
This programmatic EIS does not commit the drilling of
wells and that future actions will require specific
EIS's and both ERA and Corps permits.
Conservation and Environment would like to concur.
-------
"omments/31
DEPARTMENT OF STATE
Washington, D.C. 20520
BUREAU OF OCEANS AND INTERNATIONAL
ENVIRONMENTAL AND SCIENTIFIC AFFAIRS
January 29, 1981
District Engineer
U.S. Army Engineer District, Buffalo
1776 Niagara Street
Buffalo, New York 14207
Attention: Regulatory Functions Branch
Dear Sir/Madam:
The Department of State has reviewed the Corps of Engineers'
and the Environmental Protection Agency's "Draft Programmatic
Environmental Impact Statement: U.S. Lake Erie Natural Gas Resource
Development" and would like to offer the following comments.
dos-1 fPa9e xii, S.030: The discussion should be strengthened relative to
the 0.5 mile limitation regarding the proximity of drilling operations
and underwater gas and glycol pipelines to potable water intake.
This would include discussion of the effects of water current
patterns in relation to accidental release of contaminants,
routine discharges and pipeline breaks; and a statement regarding
the degree of certainty to which the assurance can be given
that nothing will happen to potable water supplies.
DOS-2 ( Page 1-85, 1.120: Regarding the discharge and disposal of hazardous
wastes, we would inquire as to whether the waste management strategy
mentioned here must conform to that of the Great Lakes Water Quality
Agreement. If so, it should be discussed fully.
DOS-3 f Page 1-99, Table 1-35: Do the disposal plans for CaCl2 and polybrine
fluids mentioned in this section refer to onshore disposal solely
in the U.S.? Similarly, will accidental releases of small amounts
^ of materials in Lake Erie affect solely the waters of the U.S.?
DOS-4 | If there is reason to believe that Canada may, in some way, be impacted
those impacts should be addressed in an environmental review document
in accordance with Executive Order 12114, "Environmental Effects
Abroad of Major Federal Actions."
DOS-5 f Page 4-15, 4.029 discusses potential impacts on inshore spawning
I grounds. Is there a possibility that accidental releases of material
^ to the Lake may affect these areas in Canada or the U.S.?
DOS-6 ( Page 4-16, 4.032: The local impact on phytoplankton and zooplankton
I from resuspended sediment from pipeline construction activities should
I be clarified.
-------
omments/32
- 2 -
DOS-7 r Pa9e 4-17, 4.037: To better understand the possible impacts on
plankton organisms from fluid releases, the text should clarify the
I expected concentration of HC1 and the frequency of release.
D0S-8 fPage 4-17, 4.037: It would be helpful to clarify this section by
j describing examples of various chemical releases and the subsequent
I probable impacts on plankton organisms.
In general, the Department found the DEIS to well done. We
appreciate the opportunity to review the draft and look forward to
receiving copies of the final EIS. •
Sinctftely,
Donald R. King ^"•
Director, Office of
Environment and Health
-------
Comments/33
DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
MAILING AODRESSt G-W5"*1
U.S. COAST GUARD
bo
2 6 JAN 1981
Mr. Arthur Marks.
Department of Army
Buffalo District
Corps of Engineers
Buffalo New York 14207
Mr.Marks:
CG-1 f We appreciate the opportunity to review the draft prograirmatic
environmental statement, U.S. Lake Erie Natural Gas Resource
I Development, and offer no oonment at the present time.
William M. MCGOVEIN
Chief, Environmental Inpact Brach
SPCCO
LIMIT
55
Ifa m law wm
tan Hvi wHh,
-------
'omments/34
Wulfii'i.Wi Station
P. 0. Box 531
Foinriew, Pa. 16413
1-05-81
Mr. Arthur Marks
Department Of Army
Buffalo District
Corps of Engineers
Buffalo, New York 11207
Dear Mr. Marks:
Attached is my commentary upon review of. the C.O.E.'s
Draft E.I.S.- on Lake Erie offshore gas resource
development.
Sincerely ,
Roger B. Kenyon
Lake Erie Research Unit
Mr .
S.
Hood
Mr.
V.
Mudrak
Mr.
D.
Graff
Mr.
J .
Miller
-------
"omments/35
Commentary on Draft Programmatic E.I.S. - offshore gas
resource development, Lake Erie.
Reference to:
PFC-1
PFC-2
PFC-3
PFC-4
3-12, 3.043 An atlas specifically delineating spawning and
nursery will be available shortly from Great Lakes
Fishery Laboratory, USFWS, Ann Arbor; contact person;
Ms. Carol Goodyear.
3.0-54 Walleye are caught at a rate greater than described,
certainly more than "occassionally".
3.055 Bait fishery, that is the harvest of bait fishes for
immediate resale, is a large coipaent of the com-
mercial fishery not mentioned.
3.056 We are aware of continued conflicts in the area of net
entanglement on well heads. It is our information that
most well heads remain unprotected and that gas develop-
ers are not placing deflectors on any of the wells.
|Vl5,
(
PFC-5 r3-16, 3.057
PFC-6 4-13, 4.021
4.032
4.033
The statement
Commercial fi
error. Over
in 1979 by Pe
catch was 284
It is apparen
any other age
lack of detai
disturbing si
in Lake Erie
impact situat
, "In Pennsylvania, it is doubtful that
shing still takes place.", is a major
376 thousand pounds of fish were landed
nnsylvania fishermen. The value of this
,3 39 dollars.
t that no further contact was made with
ncies other than Ontario and Ohio. The
led inquiry in this area of the E.I.S. is
nee the welfare of fishing and fish stocks
is of major concern in any environmental
ion.
Resuspension of sediments becomes more than a minor
problem, in terms of nutrients, heavy metals and all
residual chlorinated hydrocarbons, when it occurs in
a chemically reducing environment; ie summer hypolimnion
of central Lake Erie.
To expect resorption of these items to modify resuspen-
sion effects at these times, especially if the source
is continous during all the phases of Reference Program,
is somewhat naive. Under anoxic conditions (less than
0.6 mg O2/I) the internal loading of phosphorous above
is equal to 111% of the external loading of this
element. In other words, it appears this document fails
to recognize the importance of even "minor" distur-
bances of bottom sediments during any potential anoxic
event in Lake Erie.
Same comment above applies here also, especially
to central Lake Erie.
-------
Comments/36
'4-25, 4.067
t
4-69, 4.208
The likelihood of a pipeline being snagged is much
greater than assumed. Gill nets are secured by hooks
or anchors weighing about 40 lbs. at both ends of a
gang of nets. Considering the area where these
nets are concentrated (42-72 feet depths) and the
number of gangs located in these areas, it is very
probable that some will snag exposed pipelines.
Considering the power of power gill net lifters,
hooks could easily rupture even cast iron lines when
being pulled off of the bottom.
This is not entirely true. Area V in Pennsylvania
waters does include often fished commercial grounds.
All phases of gas resource development
ment cover the worst as well as the mo
Based upon the performance of some of
recovery efforts, very little effort,
actions which were obvious violations
the contractors were approached by law
Obviously, monitoring on-lake recovery
effective and it is more logical to as
it easier to select the worst scenario
it will be easier to "hide" mistakes a
reviewed in the draft state-
st competent recovery scenarios,
the on-land gas development-
in"c^ses, was made to correct
of wildlife habitat, even when
enforcement representatives,
operations will be much less
sume that operators will find
of recovery, especially since
nd accidents on the open lake.
Based upon our experience with on-land gas recovery operations, we
approach the on-lake gas development program with the appropriate
caution.
-------
"omments/37
STATE OF NEW YORK
DEPARTMENT OF AGRICULTURE AND MARKETS
J. Roger Barber.Commissioner
Albany, New York 12235
January 12, 1981
Col. George P. Johnson
District Engineer
Regulatory Functions Branch
Dept. of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, NY 14207
RE: Draft Programmatic
Environmental Impact
Statement - U.S. Lake
Erie Natural Gas Resource
Development
Dear Col. Johnson:
NYAM-1
The above DEIS has been reviewed on behalf of the NYS Department
of Agriculture and Markets. The following comments are forwarded
to further your understanding of our agricultural concerns.
It is our belief that this DEIS does not recognize prime and unique
agricultural lands - which comprise a limited and valuable natural
resource - as environmentally sensitive areas. It is in the
interest and spirit of both NEPA and the federal policies reflected
below that this fact be incorporated adequately in the FEIS.
The most recent federal policy statement was issued by the Council
on Environmental Quality (CEQ) in an 8/11/80 memorandum to heads of
(federal) agencies on the "Analysis of Impacts on Prime or Unique
Agricultural Lands in Implementing the NEPA". This memorandum which
updated and now supersedes their 8/30/76 memo stated:
Determining the effects of a proposed federal agency
action on prime or unique agricultural lands must be
an integral part of the environmental assessment process,
and must be a factor in deciding whether or not to
prepare an environmental impact statement.
In addition, EPA's Administrator Douglas Costle issued a 9/8/7*8 policy
statement which stated:
-------
"omments/38
Col. George P. Johnson
Page 2
January 12, 1981
NYAM-1
NYAM-2
It is EPA's policy to protect, through the administra-
tion and implementation of its programs and regulations,
the nation's environmentally significant agricultural
land from irreversible conversion to uses which result
in its loss as an environmental or essential food pro-
duction resource.
Lastly, USDA Secretary's Memorandum No. 1827 "Statement on Land Use
Policy" (revised), 10/30/78, reaffirms federal policy to "advocate
the retention of important farmlands...wherever proposed conversions
are:
1. caused or encouraged by actions or programs of a
federal agency;
2. licensed by or require approval of a federal agency; or
3. inconsistent with local or state government plans...to
assure that such lands are not irreversibly converted
It
• • •
Therefore, please note that not only is it "state policy to preserve...
farmlands as critical environmental areas" (DEIS §3.094, pg.3-30),
but more importantly, it is federal policy. Furthermore, it is
pertinent to include agricultural lands xn Table 1-7, "Summary of
Factors That Constrain The Reference Program", under the heading of
Sensitive Areas (pg. 1-30). We expect this inclusion would also
pertain to the restraints described in Section 4.002 of Chapter 4:
s"CONSEQUENCES OF THE PROPOSED ACTION AND ALTERNATIVES" (pg. 4-1).
It is obvious that we are concerned with maintaining NYS's natural
agricultural resource base. Northeast agriculture has increasingly
been subject to non-agricultural development from a broad spectrum of
development activities. The. importance of maintaining this resource
base - which currently stands at about 5 million acres in agricultural
production, out of a total of 30.6 million acres; less than 129,000
acres are in commercial orchard/vineyard production - is evident. In
addition, current energy trends have helped create a more competitive
climate for potential northeast agricultural self-sufficiency.
Economically, this supports the need for maintenance of this land .
resource base.
As you are aware, our agricultural lands along the shore of Lake Erie
are predominantly in vineyard and fruit production (unique farmland),
due to the micro-climatic effect of Lake Erie. Several agricultural
districts have been formed along New York State's shoreline (see
attachment). This supports our expectation that agricultural lands
in this area, upon site-specific investigations of county soil surveys,
meet USDA-SCS criteria for prime and unique farmland. Moreover, the
importance of assessing this agricultural land as an environmentally
sensitive area is reflected/required in the federal policies cited
above. (For additional state mandates see NYS Constitution, Article 14,
Section 4 and NYS Agriculture and Markets Law, Article 25AA, Section
300.
-------
Comments/39
Col. George P. Johnson
Page 3
January 12, 1981
NYAM-3
We would also be concerned if applicants proposed to dispose of
any solid wastes (dredged-filled material, etc.) on active agricultural
lands. For your information, NYS DEC rules and regulations concerning
solid waste disposal sites state that: "solid waste management
facilities shall not be placed on agricultural land designated
Class I and/or Class II land (NYS Inventory of Soil and Water Conser-
vation Needs, 1967)...within an agricultural district formed
pursuant to the Agriculture and Markets Law." (NYCRR Title 6, Part
360.8, (1)). With respect to established Agricultural Districts, it
is the policy of all NYS agencies
"to encourage the maintenance of viable farming in
agricultural districts and their administrative
regulations and procedures shall be modified to this
end insofar as is consistent with the promotion of
public health and safety and with the provisions of any
federal statutes, standards, criteria, rules, regulations,
or policies, and any other requirements of federal
agencies, including provisions applicable only to
obtaining federal grants, loans, or other funding."
(NYS Aqriculture and Markets Law, Article 25AA, Section
303.3)
We appreciate this opportunity to comment. If we can be of any
further assistance, please do not hesitate to contact us at (518)
,457-2713.
Sincerely
LOUISE A. INGLIS
Rural Development Specialist -
Environmental Resource Management
LAI/km/bas
cc: Gregory H. Sovas
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Comments/40
Robert F. Flacke
Commissioner
State of New York
Department of
Environmental Conservation
Albany, New York 12233
January 12, 1981
Dear Sir:
Enclosed herewith are the official New York State comments on the
draft programmatic environmental impact statement: U.S. Lake Erie
Natural Gas Resource Development.
As the natural resource development agency in New York State and
the lead agency for the potential development of natural gas from Lake
Erie, the Department of Environmental Conservation has reviewed in detail
the content and recommendations of the draft environmental statement. In
that regard, my staff sent letters to seventeen state agencies and some
seventy interested parties soliciting both general and detailed comments.
This submittal, includes coiranents from a number of both state and local
agencies, as well as public groups likely to be affected or having an
interest in Lake Erie development.
We believe that the draft statement represents a sincere effort to
encompass the many varied concerns with development of the Lake, and
responsible staff should be congratulated for the overall quality of the
document. In addition, we believe that the document is comprehensive in
scope and, in general, reflects a technical understanding of the proposed
actions and their alternatives, a sensitivity for controversial issues,
and an appreciation of the collective need to protect a very fragile
environment while developing a critical natural resource.
We have several imperative concerns, however, that we believe must be
more fully addressed in the final environmental impact statement:
1. Waste Discharges and Disposal
Our greatest concern for adverse environmental impacts from
this program center on the issue of waste discharges and
disposal of residuals. At the same time, the ambiguous
classification of all drilling and formation fluids as either
"hazardous" or "special" imposes an overwhelming constraint
on the environmentally safe development of the Lake's natural
gas resource. We note that under the Resource Recovery and
Conservation Act, the term "special" wastes has now been
eliminated with respect to oil and gas drilling wastes. There-
fore, we recommend that you reevaluate and update the draft
environmental impact statement using the Canadian experience as
a model to more definitely discuss both discharges and disposal
of natural gas development-related wastes.
DEC-l
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"omments/41
District Engineer
2.
/
DEC-2
\
DEC-3
DEC-4
2. Water Supply
As Commissioner of the Department of Environmental Conservation,
my first concern must be the protection of the Lake as a source
of potable water. Many communities in Erie and Chautauqua Counties
rely on Lake Erie for their water supply. These communities have
pointed out that even minimal disturbance at their water intakes
could cause serious disruption to their treatment facilities. We
have assured these communities that the Department of Environmental
Conservation will not undertake or support any program of develop-
ment in Lake Erie that .does not provide for the adequate protection
of the water resource. Therefore, we request that the water supply
aspects of the document be expanded to include a discussion of the
Canadian experience with any water supply problems and, if any,
how these problems were resolved.
3. Canadian Experience
In general, we believe that more effort should be directed toward
the experiences of the Canadian government. With some 1300 wells
actually drilled and in production, the Canadian experience
represents a full-scale, real-life working model for study. The
history of Canadian development and its successes, accidents and
problems should provide actual measurements and observations of
environmental impacts that can only be hypothesized for the
Reference Program.
4. Reference Program
In general, we believe that the Reference Program is compatible
with our present concept of prudent development of this resource.
However, it should be understood that the Reference Program is
comprised of a set of operational assumptions that have been
hypothesized to enable meaningful extrapolation of impacts and
a realistic analysis of results. Under no circumstances should
the Reference Program be perceived as a firm plan that will in
any way restrict the prerogatives of state government to deviate
from the noted Program. It is the state governments that have
the overall authority and responsibility of implementation of a
natural gas development program.
5. Interagency Task Force
DEC-5 /
While we fully agree with the objectives in recommending an
Interagency Task Force to develop uniformity of administrative
procedures and "one-stop" state entities to coordinate permit
functions, we believe that these objectives cannot realistically
be achieved. State regulatory responsibilities and business
procedures vary from state to state. Such an organization will
only add to the federal-state bureaucracy. New York State's
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"omments/42
District Engineer
3.
DEC-5
DEC-6
Uniform Procedures Act - already in place - accomplishes much
of what we believe can be expected of a "one-stop" concept.
Again, the responsibilities of leasing and development in the
Lake rest with state government. If coordination among states
is necessary and desirable, then the state agencies should work
together to resolve any outstanding conflicts. Our experiences
with the federal leasing and development of the Outer Continental
Shelf have indicated that the federal permit agencies, such as the
Environmental Protection Agency and the Corps of Engineers, should
evaluate their own permit procedures to shorten the time periods
for review and approval of applications.
~
We recognize that a great deal of work must be accomplished by the
State of New York before leasing and development of the Lake could take
place. Rules and regulations must be drafted, leases and leasing systems
must be developed, public hearings must be held, and new staff must be hired
and trained to oversee the environmentally safe development of Lake Erie.
I can assure you that this State will not move forward until we have resolved
our outstanding concerns.
We believe, however, that the Canadian experience has generally
demonstrated that natural gas development in the Lake can be accomplished
in an environmentally sound manner.
Enclosed are both general and detailed corranents and questions for your
consideration.
We look forward to the continued cooperation of your agencies in this
most important effort to help New York expand its production of indigenous
energy supplies.
Enclosure
District Engineer
U.S. Army Engineer District, Buffalo
1776 Niagara Street
Buffalo, New York 14207
Attention: Regulatory Functions Branch
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"omments/43
New York State Department of Environmental Conservation
Division of Lands and Forests
Bureau of Mineral Resources
Technical Questions and Comments on the
Draft Programmatic Environmental Impact Statement:
P.S. Lake Erie Natural Gas Resource Development
January 12, 1981
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Comments/44
General Comments on the Reference Program
As in any program based on a hypothetical set of assumptions, the Reference
Program progresses in a manner more orderly than can be expected. While many
of the basic assumptions are purposely conservative, their synthesis has
produced some exceptionally optimistic results. For instance, the program
describes timely leasing of all available acreage by a very few exceedingly
fortunate companies who experience no competitive interference and who im-
mediately proceed to drill every tract with predictable success. Their
development programs appear to be undisturbed by other factors such as
competitor pressure, availability of capital, and alternative investment
opportunities. Additionally, the development programs appear to be immune from
such accidents as a gamblers' run of dry holes or economic recession.
It would be more realistic to expect slow and selective leasing, cautious
drilling, delays for program evaluation, delayed construction of pipelines and
gas treatment facilities until sufficient reserves are proved, and overall
incomplete development.
Since all such delays will reduce net present value, rate of investment
return and revenues accrued to the States, we recommend that you include in
both "Summary" and "introduction to the Reference Program Concept" sections of
the final statement, a statement strongly emphasizing that the Reference Program
represents only one of many scenarios for profitable, environmentally safe
exploitation of Lake Erie's natural gas resources. Likewise, it should be
stressed that the profits, revenues and impacts expected from the Reference
^Program are only rough estimates.
There are other areas in which the Reference Program may be overly rigid:
designation of restricted areas, leasing procedures and well spacing. Among
the restricted areas that should be reconsidered are the shoreline buffer zone,
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Comments/45
- 2 -
the state boundary buffer zones and the potential sand and gravel areas.
Unnecessary loss of these areas would constitute waste.
We believe that a half-mile shoreline buffer zone will produce benefits
nearly equal to those of a mile-wide zone, the exceptions being that drilling
rigs will be more visible from the shore and more often encountered by recrea-
tional boaters. In view of the small number of rigs expected to be active on
the lake, these small, possibly adverse, Impacts do not warrant the loss of such
a large potentially productive area.
Additionally, no compelling reason was offered for the exclusion of a
one-mile wide band straddling interstate and international boundaries.
Certainly the States can negotiate acceptable leasing and offsetting procedures
along their common boundaries, and quite possibly, the State Department can do
the same for the international boundary.
We see no obvious reason why potential sand and gravel development areas
should be restricted, aside from an arbitrary preference for one resource over
another. With proper control, both resources can be developed with little
mutual interference.
While it is true that 640-acre spacing appears to generate the greatest
profit and the least adverse impacts, we would like the Final EIS to consider
development on 160-acre spacing. In view of the "minor", "localized" and
"temporary" Impacts predicted for most routine activities, it seems likely that
closer spacing will not significantly increase the burden on the environment.
Also, individual operators may find the closer spacing, and the compacted pay-
out interval, more advantageous.
Of the leasing procedures recommended, we do not fully understand the
concept or purpose of the "Lease Areas," but oppose delineation of large areas
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Comments/46
3 -
DEC-12
for the purpose of restricting bid proposals or the use of certain types of
equipment. Tracts should be offered for leasing as they are nominated by
potential bidders, awarded to highest bidder by tract; the type of'equipment
used to develop each tract should be determined by the physical characteristics
of each tract, on a case-by-case basis.
DEC-13
DEC-14
DEC-15
General Comments on Waste Discharges and Disposal
S The question of waste discharges and disposal must be resolved by the
respective federal and State agencies before leasing of the Lake can proceed.
In particular, the classification of these wastes must be discussed in
more detail. In the Niagara Frontier, landfill sites for the disposal of
hazardous wastes are at a premium and establishing new sites is difficult. He
believe that these landfills should.be observed for truly hazardous wastes.
To our knowledge, there is no substantiation of the implication that drilling
wastes are, in fact, hazardous.
*
' Within the document, there also appears to be some discrepancy involved
with the methods prescribed for the' disposal of drill cuttings. Under certain
circumstances, the reference program permits their discharge directly to the
lake floor, while under other circumstances, the reference program specifies
removal to shore disposal facilities. It appears from the document that the
factor governing the disposal is the type of drilling rig being utilized, i.e.,
floating or jack-up. Certainly, there must be some explanation as to why the
,mode of drilling should dictate the disposal method.
' The discharge and disposal of wastes on the Canadian side must be explained
In more detail. What are their methods and are they acceptable to the federal
and state agencies here? More information is definitely needed.
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"omments/47
4 -
DEC-16 Under Che federal Outer Continental Shelf leasing program, areas on
Georges Bank have been leased with exploratory drilling to occur shortly. One
of the continuing concerns in that area is the discharge of drill cuttings and
muds. As a result of this concern, the federal agencies have undertaken studies
to evaluate any associated impacts. He refer you to these studies in the hope
that the disposal issues may be resolved.
¦
*
DEC-17 Finally, the grouping of wastes (drill cuttings, fluids, and muds) and
their proposed method of disposal appears unreasonable. If there is a need to
dispose of a hazardous discharge, then that discharge should be remanded to a
secure hazardous waste disposal facility. However, the disposal of non-hazardous
drill cuttings may be more effectively accomplished by discharge to the bottom
of the Lake. If that method is not acceptable, the alternative means of
disposal on land could be developed. Without the hazardous waste designation,
for example, these wastes could be disposed in any permitted landfill or even
used as reclamation material for abandoned mining operations.
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Comments/48
- 5 -
Page vii, Paragraph S.007
DEC-18 c The Lockport Reefs are stratigraphic, not structural traps.
DEC-19
Page vii, Paragraph S.009
** The reference to creation of a task force to develop construction and
operation permit forms raises questions as to the activities to be regulated.
In the context of water quality, if this does relate to a State Pollutant
Discharge Elmination System permit, or its national equivalent, then permit
forms and procedures are already adopted and in place. We would strongly
suggest not inventing a duplicative procedure that would be merely confusing and
accomplish no additional purpose. Continuing in the same paragraph, there is
reference to the regulation of activities, a lot of which could be characterized
as accident prevention. This raises the subject of a spill prevention,
countermeasure and control plan with all of its attendant features as would be
required by USEPA and the U.S. Coast Guard with review and input from the
State.
DEC-20
Page ix, Paragraphs S.016 and S.017
** Constraints should be placed on construction methodolgies developers may
use so that resuspension and redistribution of sediments and toxics is held to a
minimum.
Page x. Paragraph S.021
DEC-21 f* In western New York, the solution salt mining industry which uses well
drilling and fracturing techniques to stimulate brine flow in weLl fields,
evidenced considerable minor seismic activity (which could be characterized as
the stimulation of minor seismic swarms) during drilling and fracturing
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Comments/49
- 6 -
DEC-21
activities. In one instance, a solution salt mining company was initially shut
down and subsequently put under controls as to maximum pressures which could be
stimulated through the formations to prevent the build-up of seismic stress and
the possible triggering of a major incident. These possibilities should be
explored in considering operating and development techniques for the
construction and stimulation of a gas flow from developed wells.
Page 1-20, Table 1-2
DEC-22 ( Permeability for Medina resevoirs is too high, water saturation too low.
DEC-23
Page 1-28, Table 1-7
' This section indicates that all pipelines within the 30-foot depth contour
will be buried five to ten feet below the lake bottom. We suggest that the
reference to depth of burial be deleted as it serves no informational purpose
and will be determined on a case-by-case basis. Further, this section indicates
that beyond the 30-foot depth contour, the pipeline will be secured to the lake
bottom by screw anchors. We suggest that reference to a specific technology be
deleted and replaced by a statement indicating that where necessary, pipelines
will be secured to the bottom.
DEC-24
Page 1-29, Paragraph 1.127
' *
...formation brines from Canadian off-shore gas fields are presently being
held in lagoons pending decisions on final disposal. Why? What are the
environmental risks involved?
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Comments/50
- 7 -
DEC-25
Page 1-31, Paragraph 1.051
Instead of using inflexible mud and water depth limits for jack-up rigs, we
would prefer to handle it on a case-by-case basis with the operator being
required to prove that a jack-up rig is suitable for the area.
Page 1-35, Figure 1-13
DEC-26 | Figure 1-13 would be greatly improved by adding reference points such as
roads and municipalities.
i
Page 1-37, Footnotes
DEC-27 | footnotes should also include reference to Article VII of the New York
State Public Service Law.
[¦
DEC-28
Page 1-41, Table 1-10
" The specific regulatory authorities for the miscellaneous requirements
category in Table 10 should be listed in the same detail as for other sections
of the table. A requirement for pipeline construction to withstand damage from
100-year storms should also be included.
DEC-29
Page 1-50, Paragraph 1.087
Lockport reefs (See figure 1-10 page 1-19). Considering the presented
drilling cost picture is it possible that only the Lockport reefs will be
exploited? Sulfur and hydrocarbon contamination would be expected to be higher
in the gas nroduced from these reefs and the regulatory costs to the state of
New York would be much higher and less predictable on a percent of revenue
basis. The possibility of Lockport reef (only) drilling might modify
Pennsylvania and New York interest in the Reference Project. This possibility
should be considered before approval of the project is granted.
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lomments/51
- 8 -
Page 1-50, Paragraph 1.087
Production will NOT be commingled in New York
Page 1-56, Table 1-22
' It is indicated that pipelines will be removed when wells are abandoned.
We believe pipeline removal will increase environmental impact and should not
be comtemplated except under extraordinary circumstances.
The reference program indicated fluid release from the on-land alternative
when the system is decommissioned. It is not current policy or practice to take
up pipes, but to abandon them in place. Therefore, there is no need to indicate
a possible source of impact from pipeline removal.
*
Page 1-60, Table 1-22, C.3.b
' Eight and 5/8 inch surface casing should be set at least 50 feet below mud
line in good bedrock. If this string is to serve as the water string we
recommend a minimum of 250.
*
Page 1-61, Table 1-22, E. 2.
Production string must be cemented back to surface.
Page 1-62, Table 1-22, F.
When plugging and abandoning wells, gel should be placed between all cement
plugs.
Page 1-84, Paragraph 1.116
New York State's present procedure for onshore dumping of chemical wastes
requires that they be accurately identified prior to disposal.
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Comments/52
- 9 -
DEC-36
Page 1-93, Paragraph 1.135
The program assumes production wells will be completed during the first
year and underwater pipelines and onshore gas process facilities will be
constructed concurrently with the drilling. This paragraph further states that
as soon as 25 gas wells are established in an area, plans can be made for siting
the treatment facility and pipeline routing. These two concepts seem to be
^contradictory.
DEC-37
Page 1-94 through 1-97
*" These pages discuss locational constraints and sources of environmental
impact in different phases of development. We are concerned that these
locational constraints will be interpreted as a prohibition against pipeline
construction in any but the specified areas. We believe the table should
indicate, possibly by footnote, that in some instances it will not be possible
to avoid these areas and that trade-offs may have to be made. We believe that
the table should indicate the mitigation measures that might be taken should it
be necessary to construct in these sensitive locations.
DEC-38
Page 1-98, Paragraph 1.139
The final environmental impact statement should include a system's map
showing the proximity, capacity, and direction of flow of gas pipelines of
^existing gas transmission and distribution systems.
Page 1-98. Paragraphs 1.140 to 1.146
DEC-391 How effective would state-of-the-art clean up techniques be in responding
to the various types of accidents listed?
I
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"omments/53
- 10 -
Page 1-108, Table 136
DEC-40 Net present value of production is determined using a discount rate of ten
percent. Fifteen percent is a more typical discount rate in current present
value simulations.
DEC-41
Page 1-109, Figure 1-19
S
Because of the range of possible outcomes and the uncertainties inherent in
production forecasting, use of single point estimites may be inadequate. At the
least, the single point plotted should represent the mean of all possible
outcomes evaluated for each case. A better procedure involves graphing the
entire production possibilities/revenue distribution in relation to the
probabilities associated with their occurrence, (ref. Alaska Department of
Revenue, Petroleum Revenue Division. Petroleum Production Revenue Forecast
Quarterly Report. (September 1979, pp. 23 and 24).
DEC-42
Page 1-111. 1.160
^ Model simulation run in the analysis indicates that return on investment
ranges from 13 to 100 percent and 17 to 120 percent for the 288 and 365 day
production years, respectively. Project analysis is before tax (ref. 1.158).
ROl indicated in this analysis may be at variance with recent industry and
government evaluations of offshore rates of return. According to Oxtoby, any
single well elsewhere could genera'- more gas than their existing 60 Lake Erie
wells, but that they produced a steady cash flow and 10 to 15 percent profit
regularly, as long as costs are watched intensely.
In 1979, Jack C. Threet of Shell Oil Co. pointed out that the government
was taking 70 percent of cumulative offshore revenues, while the industry's rate
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Comments/54
- 11 -
DEC-A2
of return on OCS leases was only 9.5 percent annually (ref. Oil & Gas Journal,
October 22, 1979, p. 28).
A white paper on bidding patterns, rates of return and ownership presented
in 1978 by H. Theodore Heintz indicated that of all tracts analyzed with
positive return rate, 27 percent has rates of return less than 10 percent, 40
percent had rates of return between 10 and 20 percent, 15 percent had rates of
return exceeding 30 percent. For firms ranking in the top 20 in acreage, the
highest estimated rate of return was 14 percent, (ref. U.S. Department of
Interior, presentation to the OCS Advisory Board, 12/15/78)
Page 2-5, Table 2-1
DEC-43 c Can be updated at least one year.
DEC-44
Page 2-13, Paragraph 2.044
* The productivity of existing coal carbonization (coking) plants, and the
possibility of re-establishing the proven vertical retort as, producer gas, and
water gas technology should be addressed.
DEC-45
Page 2-23, Paragraph 2.088
"* The assumption that new main transmission lines will not be necessary is
untenable. Whether new transmission facilities are needed would require an
analysis of the existing transmission system in New York counties. The results
of Columbia Gas' Case 70076 before the New York State Public Service Commission
would indicate that the document's assumption is naive.
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Comments/55
- 12 -
DEC-46
Page 2-25, Table 2-6
# ... ...
While pipeline construction will disturb the vegetation covering some
soils, there is no reason to assume significant soil erosion will result.
Maintainance of the pipeline need not result in soil erosion. Existing state
regulations require revegetation. Further, if decommissioned pipelines were
left in place no soil erosion should r"
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lomnients/56
- 13 -
DEC-50
Page 3-26, Paragraph 3.090
More up-to-date land use information for New York State is available in
regional land use plans prepared by the Niagara-Erie Regional Planning
Commission and the Souther Tier West Regional Planning Commission.'
DEC-51
Page 3-31, Table 3-9
Table 3-9 should be corrected for consistency with the latest amendment to
40 CFR 50.
1. For the gases- both ug/m 3 and ppm values should be given.
2. For TSP there is no secondary standard for the annual mean.
3. Photochemical oxidants should be changed to the ozone standard of
0.12 ppm.
This table states that the maximum standard is not to be exceeded more than
once per year; while table 3-9 gives maximum concentration "allowed once
yearly." Both tables should be made consistent with the federal ambient
standards.
DEC-52
Page 3-41y Table 3-10
' Revisions in draft population projections and associated references program
impact projections should be made as county census enumerations become final in
1981.
Page 3-47, Table 3-13; Page 3-49, Table 3-14; Page 3-50, Table 3-15
DEC 53 I These tables incorporate historic rather than projected industrial natural
I.
gas use figures. Therefore, titles should be revised accordingly.
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"omments/57
- 14 -
Page 4-32, Paragraph 4.092
DEC-54 | We question whether a 30-to-50 foot right-of-way is necessary through
I residential areas.
¦
DEC-55
Page 4-32, Paragraph 4.093
*
We find it difficult to compare impacts associated with gas facilities with
impacts associated with landfalls..
The assumption of land use conflicts is special farming areas east of Erie
has no basis. Throughout Chautauqua and Erie Counties, pipelines and gas wells
are located in orchards and vineyards. Existing access to the well and location
of flow lines respect the location of trees and vines.
DEC-56
Pages 4-33 to 4-35
¦/
To make sure impacts are controlled, noise guidelines should be
establish-d. The following limits on the one-hour energy average sound level,
L eq (l) are recommended to be applied at the nearest residence or other noise
sensitive land use:
Rural Suburban Urban
Daytime Construction 65 70 75
Daytime Production* or
Nighttime Construction 55 60 65
Nighttime Production* 45 50 55
Production facilities should not produce noticeable pure tones.
*Excluding pipeline and compressor venting. Venting should be muffled and
limited to daytime.
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'omments/SS
- 15 -
Page 4-36, Paragraph 4.101
DEC-57 f text 'las no discussion of how many facilities would be needed if
Licants had co construct their own.
r 1
lapplic
DEC-58
Page 4-51, Paragraph 4.145
"* He disagree that maintenance of a low-grass forb cover on the pipeline
corridor will usually alter the aesthetic nature of the residential setting.
The vegetation cover is normally an extension of a person's yard. Sometimes
adjacent landowners maintain the pipeline right-of-way as an estension of their
residential lawn. Also, we disagree that soil exposure offers a significant
visual impact as this is a temporary condition mitigated by a vegetation
restoration program.
DEC-59
Page 4-59, Table 4-21
S "Induced" employment was estimated using a 2.0 multiplier. This indicates
that the propensity to consume locally was 0.5. Has this been verified
empirically or assumed from other study data? In the latter case, the source
should be indicated.
DEC-60
Page 4-67, Paragraph 4.199
^ There is no proof that there would be an accelerated erosion rate modifying
the bluff landforms. This parapraph still assumes that the pipelines will be
^removed. We have previously indicated that this is not likely to be the case.
DEC-61
Page 4-68, Paragraph 4.204
^ It may not be possible to accomplish construction during seasons of low
lake level or low rainfall. It is more appropriate to identify mitigation
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"omments/59
16 -
DEC-61 I measures and personnel available to implemenc these measures should they become
[necessary.
DEC-62
Page 4-69, Paragraph 4.207
^ Lake trout and Slimy Sculpin (primary forage fish for Lake Trout) are not
discussed in the DEIS. Since well sites will (or could) be located in deep
water areas (primary habitat areas for these species) there are potential
adverse impacts that could be expected.
DEC-63
Page 4-70, Paragraph 4.213
* Selective vegetation management techniques may or may not be consistent
with the intent of maintaining vegetation that will turn brown and identify
possible gas line leaks. The statement that maintenance costs will be lower and
fewer herbicides will contaminate land and water needs some justification in the
.text.
Page A-22, Table A.l
DEC-64 ( Item 50 on page A-22 indicates that contingency spill or accidental
discharge plans are to be filed with the New York State Department of
Environmental Conservation. This item should also indicate that such emergency
plans are also required under Part 255 of the New York State Public Service
Commission's Rules on Gas Safety.
Page D-5, D.011
DEC-65 T To the list of New York regulations should be added the water quality
standards 6 NYCRR 700-704.
t
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i.omments/60
- 17 -
Page D-5, Part B
DEC-66 | Article VII of the New York State Public Service Law should be included
I under this part.
DEC-67
Page D-9, D.032, D.033, and D.034
Items D.032, D.033, and D.034 indicate areas that MUST be avoided. While
we agree with the desirability of avoiding these areas, we believe these areas
need further study. Therefore, replace "must" by "should" in this context.
It would be preferable to consider each area on a case by case basis to
allow for balancing of all environmental concerns.
Similar consideration should be given to the use of the imperative "must"
in other statements of paragraphs D.040 and D.041.
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Comments/61
o
NEW YORK STATE PARKS & RECREATION Agency Buiidmg l Fmpire Slate Pidza Albany New York 12230 inlormation 5«8 474-0456
Onn Lehman. Commissioner
1 • . • ~' !
MEMORANDUM
TO:
FROM:
Pete Buttner „
•19 th Floor • J"
NYHP-1
Steve Raiche, Director
Field Services Bureau
DATE: January 9, 1981
SUBJECT: Draft Programmatic
Environmental Impact Statement
U.S. Lake Erie Natural Gas Resource Development
Prepared by the U.S. Army Corps of Engineers and
the U.S. Environmental Protection Agency
'We have completed our review of the Lake Erie DEIS. Please incor-
porate the following statement into the joint agency letter of
response which you are preparing.
The State Historic Preservation Officer (SHPO) has reviewed the
Draft Programmatic Environmental Impact Statement concerning the
U.S. Lake Erie Natural Gas Resource Development. We have made
special note of Section 3.114, Cultural Resources, found on pages
3-38 and 3-39 of that document. We note that a cultural resource
study is currently ongoing in the "Reference Program Study Region"
which, through the development of a cultural resources predictive
model, will help to ascertain the possibility of cultural resources
being located in the project area and the potential impacts the
undertaking may have upon such resources. We will be pleased to
provide additional review and comment, in accordance with the
regulations of the federal Advisory Council on Historic Preservation
(36 CFR 800) , when further data becomes available.
If you should have any questions concerning the above comment, please
^contact Lenore Kuwik, Project Review Coordinator, at (518) 474-3176.
cc: Ivan Vamos
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comments/62
f STATE CLEARINGHOUSE
30 EAST BROAD STREET • 39TH FLOOR • COLUMBUS, OHIO 43215
• 614 / 466-7461
80-12-29
09
P
Colonel George P. Johnson
Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Attn: Regulatory Functions Branch
RE: Review of Environmental Impact Statement/Assessment
Title: Draft Programmatic Environmental Impact Statement-U.S. Lake Erie
Natural Gas Resource Development. 11 Northern Ohio Counties
SAI Number: 36-422-0010
Dear Mr. Johnson:
The State Clearinghouse coordinated the review of the above
referenced environmental impact statement/assessment.
This environmental report was reviewed by all interested State
agencies. Reviewers have not stated concerns relating to this report.
Thank you for the opportunity to review this statement/assessment.
Sincerely
JYB:rmr
cc: DNR, Mike Colvin
EPA, Mary Rhodes
-------
^omments/63
STATE CLEARINGHOUSE
30 EAST BROAD STREET • 39TH FLOOR • COLUMBUS. OHIO 43215
• 614 / 466-7461
December 30, 1980
Colonel George P. Johnson
Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Attn: Regulatory Functions Branch
RE: Review of Environmental Impact Statement/Assessment
Title: Draft Programnatic Environmental Impact Statement-U. S. Lake Erie
Natural Gas Resource Development. 11 Northern Ohio Counties
SAI Number: 36-422-0010
Dear Mr. Johnson:
Our office has recently notified you that the review of the environmental
impact statement/assessment stated above has been completed.
We have now received additional comments from a reviewing agency which
we believe should be taken into consideration as you proceed with your application
process.
Thank you for the opportunity to review this statement/assessment.
Sincerely
JYB:a1f
cc: DNR, Mike Colvin
EPA, Mary Rhodes
-------
i.omments/64
STATE CLEARir,'CHOUSE E'lYIROKMEMTAL
IMPACT STATEMENT COVER SHEET
Date Review Started SAI Nymber 3& 'i-QS'OO/O
Return No Later Than jh)t?rrrrT>flxA $rCDraft 3^
Final
Sunmary, full copy to follow
Description fronHJt rCnnrQtno'faJ? \J^icyrr>,nO^'
Agency List:
fent / ^ Number of Copies Returned
/jdurJ^^UTfK'SC/^
Ohio Environmental Protection Agency / / sstsnZ
•Attn: Beth Wolfe
Department of Natural Resources,^ cvnt fyurrrj&ctf,
/ ajstJ: jSajstti
/ Attn: Mike Colvin 0
Historic Preservation Office y! frjrry?
Attn; Bert Drennen v
- Attn: Bert Drennen
* Department of Transportation /-5CH, / /W/W
"Z" Attn: Charles Tripp u &
Department of Economic & Cormiunity Dev. I &rrct S^q 7^0?
y Attn: Bob Freedman
* Department of Health ijOwrct^ury¥adc>
* Attn: Bob Schutz &
*'¦ iiepartment of* Energy ' / ^jrtj
y Attn: Chris Schlemmer " ~ &
Department of Agriculture / jcurrd jk**7?
Attn: Ed Kirby *
j.Rrcr.iVED
No comment or further interest
2
Comnents on overleaf P^C 29 19QQ(
Comnents attached j
^ '^t C: i >"^c-C.-u r
NOV 20 1930
fV),niriv»» Or' Couucy
Oif o
-------
Comments/65
Pemms^Hvunim
State
Clewrimghmuse
P.O. BOX 1323 - HARRISBURG, PA. 17120 - (717) 787-8046
783-3133
Commonwealth
of
Pennsylvania
GOVERNOR'S OFFICE
OFFICE OF THE BUDGET
January 28, 1981
George P. Johnson
Colonel, Corps of Engineers
District Engineer
Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara St.
Buffalo, N.Y. 14207
ATTN: Regulatory Functions Branch
Dear Col. Johnson:
Enclosed are comments from the Pennsylvania Department of
Environmental Resources concerning the DEIS entitled "U.S. Lake
Erie Natural Gas Resource Development." Although the review
period has terminated, I hope you will be able to incorporate these
comments into the final EIS.
Sincerely,
Anne Ketchum
Supervisor
r
1_
-------
-omments/66
£2 W'
'¦\K
Secretary
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
P. 0. Box 2063
Harrisburg, PA 17120
January 16, 19S1
Review and Evaluation of PSCH #:
5-80-11-004
DEIS U.S. Lake Erie Natural
Gas Resource Development
Lake Erie
Anne Ketchum, Supervisor
Pennsylvania State Clearinghouse
CLIFFORD L. JONES
Secretary
Department of Enviro:
Resources
DER-1
DER-2
The Department has prepared rather extensive comments on
the Lake Eric Natural Gas Resource Development Draft Environmental
Impact Statement. We felt it was important we look closely at proposed
Federal policy in this area since the decisions made now will have a
major impact on the environment in and around Lake Erie for many
years to come.
Attached please find the Department's analysis and comments.
I would like to highlight several important points made in the comments.
The creation of a Regulatory Task Force and a single office to
manage the offshore programs as described in the Draft EIS are impractical
given thu number and varying responsibilities of the Federal and state
agencies involved. Our interpretation is that the Federal Government
is attempting to overstep its mandates in regulating Lake Erie gas
development, particularly by creating the Task Force. It is our
contention that the stale regulatory program needs to be more stringent
than standards likely to be approved by a Task Force documented by
Federal Agencies.
There is too little information on the experience Canada lias
had with natural gas development. A more complete description of the
Canadian experience in the Draft EIS would measurably aid in public
understanding and possibly mitigate public fears about developing
natural gas in Lake Eric. No examples of Canadian pollution problems
were given nor were evaluations made comparing Canadian and possible
U.S. experiences.
-------
Comments/67
Coirenents
Pennsylvania ik'|>artmont of linvironmental Kesources
Draft JUS, U.S. take Uric Natural Gas Development
Regulatory Approach
DER-3
DER-4
DER-5
DER-6
DER-7
'flic Department objects to the tone of the Draft EIS as embraced in the
projxjsal to create a joint Federal and State Regulatory Task Force to draft
legislation and minimum standards for offshore development and to the
recommendations requiring a single office to manage the offshore program.
Our interpretation of the proposal is that the Federal Government is
attempting to overstep its bounds and is trying to exert more.' than its mandated
responsibilities in development of Lake Erie natural gas. It would seem that by
establishing a Regulatory Task Force the Federal Government would gain a major
role that tiiey Jo not now have.
'Hie responsibility to maintain uniformity implies a coercive role by the
Task Force (and its federal components) that the states should not agree to.
Ke believe our state program needs to be more stringent than the one that might
he adopted by the Task Force.
Hie Federal Government should approve, as originally c-xplained hy the Corps
of lingineers, a rennit to give a company blanket approval to drill in'the Lake
and nothing more. The states should establish between themselves common lease
provisio;..' and any other agreements to aid the industry and reduce the overall
paperwork of exploration and development. Use Inderal Government should
establish jniidclines to use but inspection and approval on each phase of the
exploration should be secondary to the states' rights to Twinagc the development
of the resources in their respective states.
"llie common state lease should cover bonding, insurance, fees, contingency
plans, etc. The only competition should come from geologic :ind production
potential. If industry has a lease connion to all states, they will know how to
operate more uniformly and need not worry about two or three different sets
of state guidelines.
b
/
The Department agrees with the need for some form of Federal permits from
the Corps of Fnginecrs and the Environmental Protection Agency as noted earlier;
however, we disagree with the need and wisdom of concurrence of "local agencies,
general public - such as individuals, groups, organizations, local officials,
legislators, businesses, etc." This is more red tape. The move jieople
involved in obtaining a Federal permit, the longer it will take and the cost
ajtd delay may not he justifiable.
In addition several other promised fedora] regulations would cause
unnecessary red tape -
-------
- 2 -
- Federal permits for onshore construction facilities;
- Fedora 1 permits for a pipeline from the wells to processing
plants;
- plugging of wells producing insignil'icant amounts or oil
(.five gallons per day).
fhe one-stop state agency approach to administration of each state's offshore
-acreage is not practical. In Pennsylvania, the principal siatr: organisation for
irapleinentation of an action by industry is on the Bureau level. In addition,
review and approvals for drilling must come from other state agencies, such as
the Fish and Gai.ie Commissions. Jt would not be possible to have alJ permits,
leasing, inspection and surveillance come from one office. A single agreement
for all permits signed by the various state agencies may be possible and more
practical.
The one-stop state agency approach may have been reconiisended because of
a misunderstanding of how responsibilities for regulating offsliorc leases are
divided. Table 1-9 says the Bureau of Topographic and Geologic Survey has
responsibility for "establishing and enforcing a regulatory program for offshore
operations." In reality there is a cooperative effort between the Geologic
Survey and the Bureaus of Water Quality Management and Solid Waste Management
within the Department.
Canadian Experience
The Department feels there is too little information and analysis of Canadian
experiences and its application to the U.S. natural gas development program.
No information was given on the level and type of activity conducted by the
Canadians in order to inspect and insure safe and pollution Tree development
of their natural gas. This is a serious deficiency of the i;IS. A ciurc complete
description of the Canadian experience in the 1:.1S would measurably aid in
public understanding and possibly mitigate public fears inasmuch as the
Canadians liave been able to develop their gas without significantly polluting
Lake lirie. No examples of Canadian pollution problems were given, nor were
evaluations given comparing Canadian experiences with passible U.S. experiences.
In Canadian waters through October 1980, over 1,300 wells have been drilled.
This is more than the total of D90 (which includes producer:; and dry holes)
proposed for the states; of New York and Pennsylvania combined. Khar problems
have the Canadians had? Itow much lia:ardous waste did they generate? flow was it
disposed of? What socio-economic problems were created? (law were they solved?
In the final draft, the C'luadi;in experience should bo reviet.vd and conui.ireJ with
the program planned on the American side of Like lirie.
:V
ftis t e_ji i s|>osa 1
The classification of all spent drill in;: fluids as lui^anlous should be
reevaluated. Only those wastes which contain certain chemicals (whi.h can be
lifted) should be classified as hazardous. If all waste;; are classified as
hazardous, it may be impossible to disj>ose of onshore just because of the l;;l>el
pJaccil on the materials wiien, in fact, they are not "hazardous".
-------
i.omments/69
- 3 -
From inquiries received in Pennsylvania, there is a good chance that some of
our offshore lands will be leased by a Canadian Company. If a Canadian Company
already has a port to dock its offshore rigs and facilities to disposal of
all wastes ami fluids from the offshore wells, how will this affect the
permitting process of the Federal (knemtnent? Can the Canadians disuse of
our wastes as they see fit in their facilities located in G.nnda?
i
llie quintities of waste generated by the offshore wells seems high as shown
In Table 1-51. 'flic- source of this data should be cited, lias any of the data been
obtained iron' Canadian wells? Some of the specific values shown are questionable.
Not cab ly are the 62.07 acre-feet of sanitary waste and 43S.83 tons of domestic
waste frran the drilling of 512 wells.
The Draft F;IS rccomnends waste drilling fluid, muds and other discarded material
be disposed of onshore. Waste fluids would be injected into deep disposal we]Is
and other materials landfillcd. Presently, there are no deep injection wells
within several hundred miles of Lake Erie in Pennsylvania. There is one approved
public use landfill in Erie County. Hie specifics for the disposal of wastes
must receive further consideration in the EIS.
In the first chapter, there is a lot of information regarding salt water
and its disposal problems. Salt water should not be a problem. The report should
compare the amount of salt generated by the drilling of wells for the American
side with the amount of salt used in the Lake Erie watershed for snow removal
in the cities of Cleveland, Erie and Buffalo. Also, when discussing other wastes,
the report mentions the location of 450 outfalls from the cities and industry
along the Lake which discharge various chemicals into the lake. The report
should compare probable discharges in the Lake from offshore drilling with the
known 450 outfalls.
'The use of the value of produced water in the amount of 3 bbls. per million
cubic feet of gas production appears high. In another part of the report
(.Table 1-55), the value of 5 bbls. of water wis used. The report should list
the source of the value quoted.
Water Qiality Impacts
The Draft HIS should consider how accidents would ho contained and cleaned
up. Since there is a significant potent ial to affect publ ic water supply intakes
and recreational activities, this should be given serious cansideration in the
E1S.
' 'llie Draft EIS indicates offshore drilling in lake Krie will have a minimal
effect on water 8. However, it wist be ri.vngnized that there v.ill lie some water
tjiialily degradation at least ir. the iiinrdiate area of tl": activity. Table 1-25
on pagt 1-75 1 ists some routine drill in;1, activities 1 liat will impact on water
quality. Here again, informal ion on Canada's e*i>erience would he very helpful
ssir.c.* t'icir record in limiting environmental impacts seems to be very good.
-------
^omments/70
- ¦» -
Onsliore Alternative
DER-24
The so-called "onland alternative" to drilling in Lake Uric is actually
no alternative at all. lLxploration and development of oil and'gas around
Lake lirie is booming now and will continue with or without the leasing,
,drilling and gas development of I.ake Erie itself.
The comparison of the onshore and offshore drilling docs not mention the
point tliat develqiment of the offshore lands is more easily managed because they
have a restricted ownership (three states) which moans fewer companies will lease
the acreage, and they can be controlled by lease agreements which are stronger
tlir.ii existing laws. The onshore development is wide open with many different
companies leasing, and in fact, many people are drilling Upper Devonian slialc
gas wells in their backyards. In the December 12, 1980 issue of the Petroleum
Information, 508 wells here listed as bcuig drilled or permitted for drilling
17: tlie comities of lirie and Crawford in Pennsylvania and lirie and Chautauqua in
New York.
>
i
Mich was said about loss of vegetation at pipeline and drilling sites and
the resulting erosion. Tn all state leases, inmediatc revegetation and
restoration is required. In fact, more vegetation is often planted than was
on the site prior to drilling. Also, the P.TK states that wildlife will leave
and not return for the life of the project. In Pennsylvania, pipeline rights-of-way
planted according to lease tenns provide an important site for insects as food
for turkeys and other game birds.
['Hie de
onshore dri
fertiliser
degradation of water quality in streams was discussed as a result of
illing. I low docs the volisue of the pollution compare with the use of
by farmers or the use of fertilizer and pesticides by the homeowner?
In this section, the second reason given discouraging directional drilling
was tliat the onshore well site would have to be located a great distance inland
from the lake shore in order for the well bore to encounter offshore Devonian
and Silurian strata. To reach farther into the Lake, the onshore wells would
^ have to be located closer to tin; lake shore not farther away.
Conflicting Uses
The Draft CIS should mention the potential conflicts with sand and gravel
operations. All such operations can cither be leased as a nondovelopment tract
or they can be leased after a well is drilled and determined dry and abandoned.
If a sand and gravel operation is adjacent to a producing field, the sand and
gravel operation should be tenninnted because the natural gas reserves should
lave priority. "Ilicrc should be oilier areas within the lake which are not Ik-in;1,
s JL-velopod for oil and j>a-. finin which s:!'.i,l and gravel may k: .obtained.
f The Draft );iS should study any impact < the piv>posed Ui'ro lirie In re ret
Project (jPU and Ontario liyilro are planni";: will 1ia-/e on gas devol<'-|>iiK-nl.
'.-omuvt.
-------
comments/71
- S •
Income Estimates
'Hie lira ft lilS states thai the I'ommonweaHh o!' Pennj-yl vaui a could recci/c
$2*17,000,000 from bonus bids, rentals and royalties generated Iron the leusini:
anil production of gas in Lake Uric. Thir. estimate is basc-d upon the unrealistic
assimption that all 512 tracts available for drilling in the Pennsylvania
portion of the Lake will be leased and drilled and tliat as a result of this
drilling, 359 gas wells to 11 be completed. It is based upon the assumption
tliat economic gas discoveries will 'ue made on 70'i of the leasable area in wo J Is
spaced approximately one mile apart throughout the whole 512 square nils area.
It is more realistic to expect that exploration and drilling efforts will
be highly selective and tliat most tracts will not be leased or drilled because
economic risks will be too high. The state's experience in leasing bears this
out, both in leasing offshore tracts in/Lake Erie in 1959 and 1963 and in leasing
onshore state forest and park lands since 1947.
In 1968, the state offered 37 offshore Lake Erie tracts totaling 369,<)S<>
acres at a competitive bid oil and gas lease sale. Bids were received on only
4 tracts. The bidders were highly selective - even at a time when exploration
and drilling activity in the Canadian portion of Lake Erie was high. In 196?
a total of 32 wells were drilled in the Canadian waters. Of 21 exploratory
wells drilled, only 7 were completed as gas producers. Of 11 dcvelopuent wc.lIs
drilled, only 7 were completed as gas producers.
During the period 1947 through 197S, the str>l e had leased a total surface
svra of 684,G25 acres, mainly Cor the exploration and development of Ori.ika.iy gas
reservoirs which are much more economic to explore tlian the CI inTon-Medina
gas reservoirs in Lake Erie. From this leased acreage upon which parts of 19
Oriskany gas fields and 6 shallow gis field? ucre developed, the stare had
received only $41,511,019 a.*- ~f Jar.iiaiy 1, Uv/0 or only $01 per ;>rre lea sot!
from all oil, gas and gas storage income sources, i.e., tonus I..ds, rentals, and
royalties, over a 30 year j.ejiod. Only about one-third of the total state forest
a"d park lands in the state were leased to the oil and gas operators and most, of
this Jea.;ed acreage, more than 805, was never drilled. Certainly, this demonstrates
tliat ths oil and gas operators have been very selective in leasing and drilling
in the past and arc likely to continue being selective in the future.
Estimates of income which could result from successful rank wildcat exploration
projects, such as those in Lake Eric, are very speculative and are often misleading
and worthless. However, it seems that any estimate of the state's future income
from Lake Eric gas leasing and development activities should be based on past gas
leasing and development experience and income (adjusted for inflation and increased
gas prices), and on some optimistic assumptions, namely that initial exploration
efforts will he successful in finding economically productive gas which will
cficonragc continued drilling and development operations.
Posed on this reasoning and data from the 1 Apartment's leasini; :uid dev'.-lop-non t
operations on state lands' in Pennsylvania, the best estimte that can !-e m;:de is
that the state could conceivably realize tens of millions of dollars fioip l.:d;e
Erie gas leasing and development activities in the next two oi three decades (see
Attachment 1). Even this estimate may be too optimistic as the following
discussion indicates.
-------
wOmments/72
- 6 -
DER-26
DER-27
The economics of Clinton-Medina gas development in the U.S. portion of
lake lirie are still questionable despite the optimistic tone of the Draft HIS.
'11k; costs of drilling for and developing gas of (.si rare under the restrictions
and requirements 01 flic many government agencies will undoubtedly be high,
at J oast double the onshore costs and |>ossib1y much higher. Tliere are many
unknown cost items, such as the total cost of waste disposal operations,
pipeline burial requirements, etc., which could under certain government.
ret(tiirei^nts ncike Clinton-Medina gns development operations economically
^unattractive and too risky to undertake.
1110 Clinton-Medina gas reservoirs arc relatively small gas producers which
have a fairly long productive life. The average well can be expected to have an
ultimate cumulative yield of approximately SOO million cubic feet (mcf) of gas
during its productive life of 20 years or more. It can be expected to produce
an average of only 160 mcf per day of gas during its first year and only 50 mcf
per day of gas during its tenth year, lloncc, gas dcliverabilities
(i.e. production rates) and resulting gas sales income from the CI inton-Medina
gas wells may be insufficient to justify high offshore leasing, exploration,
drilling and development costs.
DER-28
Economically productive Clinton-Medina gas reservoirs are difficult to find
in rank wildcat areas. They arc formed by porosity developments in relatively
tight (low permeability) sandstones which are limited in areal extent commonly
by porosity pinchouts within the sandstone itself rather than by pinchouts of the
sand body. These individual traps are commonly small in areal extent, irregular
in shape and erratic in distribution and, hence, are very difficult to find even
with the use of expensive up-to-date exploration methods. The exploration risk
is somewhat decreased if an area contains a high density of these porosity
s bu.i ldups.
Mi see 11aneons Coraicnts
DER-29
DER-30
DER-31
DER-32
in the I^aVc lirie portion of
We believe this figure to be in error
offshore lands. The Pnil't UTS should
stab.l ished.
o Soi-te of the terminology defined in the ElS is not used or described in
Pennsylvania, i.e., Field, Secondary Term. The delay rental in Pennsylvania
is now S2.00 per acre per year for the first three years and $3.00 for the fourth
to tenth year. Hie percent of royalty to bo received for Pennsylvania has not
boon established. In the past, it was 12.5 percent and may remain at this value.
[*>. The
JSlufi' So
permit p
document does not reflect, the fact that Pennsylvania has passed the
Sot Back Act and tliai certain stiuctures would require a Department
pursuant to Section HIS of the Regulations.
o\ Tables Index and Table 1-20 Title should !>e "iXuiiJxts of Proposed Iv'ells
1... I . * i I ...I It - I I • *
to Ik; Drilled
(corrections underlined).
o I.ast sentence in Section 1.090, page 1-53 should read: A tally of the proiiosed
total productive and nonproductive wells to be drilled in each state is ..."
(corrections underlined).
-------
v,omments/73
- 7 -
u
DER-32 | 9 I'igures Index and Figures for Figures 1-16, 1-17, 1-18 and 1-19 should
include the words "proposed" and "to lie."
DER-33
t In Section 1.034, page 1-1.7, the statement that "the Clinton-Medina
sandstones form a blanket deposit ... and will likely produce gas throughout
its extent" is wry misleading. The CIinton-Medina is not a blanket sandstone
which "will likely produce gas throughout its extent." Gas is fotind in
erratically distributed stratigraphic traps formed by porosity buildups in the
sandstones.
DER-34 f ® 'Hie Table Index and Table 1-1 on page 1-8 should be entitled "Lake Erie
I Ixind Area" (corrections underlined).
DER-35 | • The Table Index and Table 1-5 on page 1-27 should be titled "Estimated
I Production of Gas Per Average Well (correction underlined).
DER-36 f ® In Sections 1.001 and 1.002, the historical summary should mention that
I approximately l,30i) wells have been drilled in the Canadian waters of Lake T-rie
I and two wells have been drilled in Pennsylvania waters without any significant
1^harm to the environment.
-------
tiojnnients/74
At LaclKiOnt 1
ESTIMATE OF lUlURH INCOME
to camwuTii of ri-NNSvr.VANiA
FROM GAS LEASTMG ANT) VIEVEljOPMENr
IN MKF. BRTE
Department of Environmental Resources
Using Optimistic Assumptions
Income Estimate
"(1) Bid Bonus Income - — - - $ 16,334,000.00
Assuming all 512 drillahle tracts, totaling
327,680 acres are leased at an average rate
of $S0 per acre.
327,680 acres x $S0/ac ¦> $16,384,000
(2) Rental Income - -- - $ 6,881,280.00
Assuming that rentals are paid on the
average tract for 7 years at a rental
rate of $3 per acre.
327,630 acres x $3/'ac x 7 yrs. = $6,881,280
(3) Royalty Income $ 56,250,000.03
Assuming that initial exploration efforts
are successful in finding economically
productive gas which will encourage
continued drilling ;uid development
operations.
Assuming that 50« o£ the tracts arc drilled
and that gas is produced from 70". of the
tracts drilled (using one well per tract)
512 tracts x 50s drilled - 256 tracts drilled
256 wells x 70» success ratio - 180 gas wells
Assuming a royalty rate of 1/8 of the pre-
vailing wellhead price of gas at $5 per mcf*
(average) and an average ultimate yield per
wll of 500,000 mcf during its productive
life of 20 years or more.
180 wt-lls x 500,0P0 ircf/well » 90,000,000 mcf total
90,000,000 mcf x $5/mcf average - $450,000,000
$450,000,000 x 1/8 royalty - $56,250,000
ESTIMATED T0TAJ. FU1URE INCOME TO STATE $ '0,?15,280.00
^5/incf is the assumed average wellhead price of gas which
: increases fro.r. $2. S(>/mo T to*T7. SO/mcf (a 200:; iutreu'-o)
over a period of 20 years or more. I vo'i with rani;¦,u-t
inflation lesiiltinj', in a gas pviiv increase from S':.jO/mcf
to $27.50/iicf (a l'MC, increase) with an avenge :.;as pr io-
of $15/i:icft th< total royalty income to the Stai? ivun'u
only he $U>S,750,000.
{ '0,000,000 mcf x $15/nrf x 1/8 - $108,750,00'))
Ol" course, wtc.li bi" the fi.tn-.rc royalty iiKor.k' v.i 1: hi in inflaivJ
liol.iars worth much, le.-s in buying ]xwr titan tho pros-.-n¦ ) do! Jar.
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^omments/75
STATE CLEARINGHOUSE
30 EAST BROAD STREET • 39TH FLOOR • COLUMBUS. OHIO 43215
• 614 / 466-7461
February 4, 1981
Colonel George P. Johnson
Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, Mew York 14207
Attn: Regulatory Functions Branch
RE: Draft Programmatic Environmental Impact Statement - U. S. Lake Erie
Natural Gas Resource Development. 11 Nothern Ohio Counties
State Application Identifier Number (SAI): 36-422-0010
Dear Applicant:
Our office has recently notified you that the A-95 review has
been completed with respect to the above referenced project and recom-
mended that you proceed with an application to the appropriate federal
funding agency.
We have now received additional comments from a reviewing agency
which we believe should be taken into consideration as you proceed with
the application process, (see attached)
If you have any questions concerning the above, please contact
our office, (614) 466-7461.
Sincerely
•Oudith Y. Brachman
Administering Officer
STATE CLEARINGHOUSE
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.omments/76
Ohio Department of Natural Resources
Fountain Square • Columbus. Ohio 43224 -(614) 466-3770
January 20, 1981
Colonel George P. Johnson
District Engineer
U.S. Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
RE: DRAFT ENVIRONMENTAL STATEMENT - U.S. LAKE ERIE NATURAL GAS DEVELOPMENT
Dear Colonel Johnson:
The Department of Natural Resources has completed a review of the
above-referenced environmental statement. The attached comments are the
result of an interdisciplinary review process coordinated by the Office
of Outdoor Recreation Services.
We appreciate the opportunity to provide these comments. If you have
any questions, please do not hesitate to contact my office.
ROBERT W. TEATER
Di rector
RVIT/jd
Attachment
cc: Judith Y. Brachman, Administering Officer
State Clearinghouse
JAMES A. RHODES. Governor • ROBERT W. TEATER. Director
-------
-jmments/77
"SAX* 2>(o' V^?<2 ' °0/0
Fountain Square - Columbus. Ohio 43224 • (614) 466-3770
January 20, 1981
Colonel George P. Johnson
District Engineer
U.S. Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
RE: DRAFT ENVIRONMENTAL STATEMEJIT - U.S. LAKE ERIE NATURAL GAS DEVELOPMENT
Dear Colonel Johnson:
The Department of Natural Resources has completed a review of the
above-referenced environmental statement. The attached counts are the
result of an interdisciplinary review process coordinated by the Office
of Outdoor Recreation Services.
We appreciate the opportunity to provide these comments. If you have
any questions, please do not hesitate to contact my office.
Sincerely,
ROBERT W. TEATER
Director
RWT/jd
Attachment
cc:«/)udith Y. Brachman, Administering Officer
State Clearinghouse
JAMES A. RHODES. Governor • ROBERT VI TEATER. D*»cror
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comments/78
am
Ohio Department of Natural Resources
Fountain Square • Columbus. Ohio 43224 • (614) 466-3770
December 17, 1980
ODNR-1
ODNR-2
Col. George P. Johnson, District Engineer
U.S. Army Engineer District, Buffalo
1776 Niagara Street
Buffalo, NY 14207
Dear Colonel Johnson:
I -am writing you in reference to the recently released Draft
Programmatic Environmental Impact Statement entitled "U.S. Lake
Erie Natural Gas Resource Development." Specifically, I wish to
comment on Summary Items S.009(e), S.010, and S.011.
S.009(e) - The establishment of a state/federal regulatory
task force is not necessary and would add another layer of red
tape. In order to have authority, the task force would require
legislation from the three states and the Congress. Our
experience is that it would take several years to obtain the
legislation. Ohio already has the technical expertise and legal
authority required to develop all administrative aspects of
permitting, regulating, and managing drilling of State owned gas
resources under Lake Erie. We presume Pennsylvania and New York
^have similar authority.
[
S.010 - In contradiction to the EIS, Ohio presently has
legislative authority to lease gas in Lake Erie. This obviates
the need for new legislation.
ODNR-3 f S.011 - We would object to any federal directive which tells
I us we must use a "one office" approach. We will develop our
[^permit system to best serve Ohio.
In summary, the state/federal task force as proposed in the
EIS is unacceptable to Ohio.
ROBERT W. TEATER
Director
RWT/law
cc: Pennsylvania
New York
JAMES A. RHOOES. Governor ~ ROBERT W TEATER. Director
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comments/79
ODNR
Ohio Department of Natural Resources
Fountain Square • ColumBus. Ohio 43224 • (614) 466-3770
COMMENTS ON DRAFT ENVIRONMENTAL STATEMENT
U.S. LAKE ERIE NATURAL GAS RESOURCE DEVELOPMENT
(Corps of Engineers, Buffalo District - U.S.E.P.A., Region V, January 1, 1981)
odnr-4 Generally, the draft programmatic environmental impact statement (DEIS)
adequately discloses potential environmental impacts of the development of
natural gas reserves in the U.S. portion of the central and eastern basins
of Lake Erie. Although the environmental impacts are properly identified,
the Department does not agree with all aspects of the evaluations of these
impacts (refer to specific comments). We do, however, feel that the DEIS
satisfies the requirements of the National Environmental Policy Act (NEPA)
^ of 1969, in particular Section 102(2)(C).
odnr-5 Under state law, Ohio Revised Code, Title XV, Chapter 1505, authority is
granted to the Department of Natural Resources to issue permits or make
leases to parties making application for permission to remove sand, gravel,
stone, gas, oil and other materials or substances from and under the bed of
Lake Erie. We have the technical expertise needed to develop all adminis-
trative aspects of permittinq, regulating, and managing drilling of state
^ owned gas resources in Lake Erie.
odnr-6 f The formation of a task force from the three states and federal agencies to
develop standard lease forms, drillinq permit forms, and construction and
operational forms is unnecessary. Each state has or should develop forms and
and regulations which would provide for the most efficient and safe extraction
of gas from that portion of Lake Erie within Its jurisdiction. Permits and
regulations should be specific and designed on conditions existinn within
the jurisdiction of each state. In Ohio, the development of a lease plan
^was started many years ago and could be implemented when desired.
odnr-7 f The key to a successful offshore well drilling program is coordination. In
light of the several federal, state and local agencies that would be involved
statutorily in the program, interagency coordination is imperative. However,
this process should be ancillary to the operations of the responsible state
^ agency.
JAMES A. RHODES. Governor • ROBERT W. TEATER. Director
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-omments/80
-2-
ODNR-8
There are good reasons for the regulatory authorities of the involved federal
agencies and their mandate to carryout federal NEPA responsibilities. It
1s our hope that the authorization of certain standard development activities
can be simplified through processes such as nationwide and general permits
where appropriate. We believe that each State can and should coordinate as
many aspects of the federal regulatory programs as possible; ensuring that
applicants are fully aware of federal requirements. The NEPA determinations
would be made by the Corps of Engineers on a case by case basis.
SPECIFIC COMMENTS
Summary
ODNR-9
ODNR-IO
ODNR-11
Page vi, S.007 - The Reference Program assumes a well spacing of one well
on every 640 acres (a tract). This could be reduced to 320 acres, 160 acres
or less depending on the permeability encountered at different localities.
^Wei 1 spacina is a matter to be determined by the appropriate State agency.
Page vii, S.009 - The establishment of a state/federal regulatory task force
is not necessary and would add another layer of red tape. In order to have
authority, the task force would require legislation from the three states and
the Congress. Our experience is that it would take several years to obtain
the legislation. Ohio already has the technical expertise and legal authority
required to develop all administrative aspects of permitting, regulating, and
managing drilling of State owned gas resources under Lake Erie. We presume
Pennsylvania and New York have similar authority.
(
Page vii, S.010 - In contradiction to the EIS, Ohio presently has legislation
authority to lease gas in Lake Erie. This obviates the need for new legis-
lation.
ODNR-12 fPage viii, S.011
1^office" approach.
¦ We would object to any directive that we must use a "one
We would develop our permit system to best serve Ohio.
ODNR-13 f*3?6 X1» S.023 - Open drilling season: The periods should be flexible. In
I Ohio, open and closing dates can be determined by the responsible Division
l^of the Department of Natural Resources.
Chapter One
ODNR-14
ODNR-
-c
'Page 1-17, 1.033 - The impact statement suggested strongly that abundant gas
1s only expected from wells in central and eastern Lake Erie. Many geologists
believe that downdip from the production in the Canadian portion of Lake Erie,
oil will be found in the Clinton-Medina sequence (Clifford, 1975, p. 7).
Page 1-31, 1.052 - Hazards discussed in this item are hazards encountered in
exploratory drilling, not geologic hazards.
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Comments/81
3-
odnr-16 fPage 1-34, 1.959 - Included in the offshore sensitive areas should be the
I leased salt mining areas and future projected areas for mining under the
Llake in the Cleveland and Painesville, Ohio, areas.
odnr-17 Page 1-36, Table 1-9 - It is not believed that the expertise to coordinate
all environmental and gas-related activities can be assembled under a single
designated state agency (offshore program office). Each state should develop
the coordination program which functions best within the state's governmental
framework.
odnr-18 fPage 1-37, 1.063 - The creation of a regulatory task force representing the
three states and appropriate federal agencies is unnecessary. Each state
has its concerns and conditions for development of gas from the lake and
a set of regulations and permits which would be suitable for the entire lake
region might not be appropriate for any individual state. Lease forms, permit
Jxirms are best left up to individual states.
ODNR-19 fPage 1-39, Table 1-10 - This table is an excellent summarization of environ-
mental standards and should form a framework for individual state rules and
^regulations.
ODNR-20
ODNR-21
ODNR-22
ODNR-23
[Page 1-46, 1.073 - This assumption of the Reference Program that the lake gas
will be a commodity marketed through interstate commerce is not valid for the
State of Ohio, and therefore, pipelines would be exempt from U.S. Department
of Transportation regulations.
Page 1-51, Table 1-16 - Leasing areas: The smallest leasable unit of one
minute latitude by one minute longitude (tract) is not recommended. A
minimal leasing unit should cover the area within 5 minutes longitude
(Block) except along the southern, northern and eastern periphery of the
Lake Erie lease area where the lease Blocks are reduced in size.
Page 1-53, 1.092 - Throughout the DEIS there is a constant referral to Lockport
Reefs as an important target horizon for the production of gas. Assumptions
are made that it is a more productive and more economic fomation to explore.
Examination of the maps "Oil and Gas Fields of Ohio, 1974" published by the
Ohio Division of Geological Survey indicated discoveries are widely separated
and generally involve small fields. Reference is made to Figure 1-1 in which
14 lease areas are recommended, (the text states there are 16). Areas VIII,
XII, XIII, AND XIV are specifically designated as Lockport Reef Areas. On
what evidence are they defined? Particular reference is made to Area XIV
located adjacent to Lorain County where there is no proven Lockport production.
JJith due respect to the Mesolella study of 1978, this is a misleading projection.
Page 1-103, 1.142 - The statement "that since no suitable empirical data are
available with reference to anticipated hazards or accidents from existing
offshore freshwater natural gas development programs" does not take into
account the natural gas development program in the Canadian portion of Lake
L»Erie.
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i,omments/82
ODNR-24
ODNR-25
ODNR-26
ODNR-27
ODNR-28
ODNR-29
-4-
Page 1-113, 1.162 - It is believed the cost of onshore transportation of waste
between dock and treatment disposal facility can be considerable and should be
included in the total cost of developing Lake Erie gas.
Chapter Three
f"Page 3-10 to 3-17, 3.035 to 3.057 - Items on aquatic biology, region streams,
l^and water use appear to be adequately covered.
Page 3-15, 3.056 - Ontario's commercial trawl nets have had problems with
gear entanglement on unused or plugged wells. They have had success with
well deflectors. Wells here do not present a problem to gill nets, the
^principal gear used in Ohio's central basin waters.
Page 3-17, Table 3-3 - Concerning water intakes, the Diamond (Alkali) Shamrock
Company plant is abandoned. The water intake facility was donated to Lake
County Board of Commissioners.
Chapter Four
'Page 4.67, 4.199 and 4-69, 4.205 - The statement on intermingling aquifers
is misleading. For the most part, the area of Lake Erie under consideration
has no potable rock aquifers. The pre-glacial buried valley underlying Lake
Erie could contain fresh water aquifers but this unconsolidated material will
be cased off by the 16 inch drive pipe.
V,
Appendix D
'Page D-8, D.027 - It is the Department's position that a uniform (one-mile)
buffer strip along the shoreline is not appropriate. The width of the buffer
zone would vary from place to place. Along certain stretches of the shore-
line a greater width may be required, hov/ever, there are areas where a one-mile
buffer may not be needed and natural gas reserves would likely be found. A
buffer strip of varying width would be established by the Department to meet
the management needs of the program.
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Comments/83
®M®ffifisG®p0© [pposcgFwsi'GEtom (DffffBcs®
Ohio Historical Center 1-71 & 17th Avenue Columbus, Ohio 432TI (614) 466-1500
A-95 REVIEW COMMENTS
S.A.I. No. 36-422-0010
Draft EIS - U.S. Lake Erie Natural Gas Resource Development
As noted in the EIS, the proposed Lake Erie Natural Gas Resource Development
has potential for affecting cultural resources of possible significance.
These resources include prehistoric and historic sites on land and underwater.
The Ohio Historic Preservation Office would like the opportunity to review and
comment upon the cultural resources study..
In addition, the Regional History/Architecture and Regional Archaeological
Preservation Offices of the Ohio Hiscoric Preservation Office which cover counties
to be affected by the proposed development should be contacted for input into
the cultural resource study. These offices are listed below:
History/ Region 1HA - Ted Ligibel and Cynthia Barclay, Center for
Architecture Archival Collections of Bowling Green State University, jth
Floor, University Library, Bowling Green, Ohio 43403,
(419) 372-2411. Counties: Defiance, Fulton, Henry, Lucas.
Ottawa. Sandusky. Williams, and Wood.
Region 2HA - Eric Johannesen, Western Reserve Historical Society,
10825 East Boulevard, Cleveland, Ohio 44106, (216) 721-5722.
Counties: Ashtabula. Cuyahoga. Erie. Geauga, Huron, Lake, Lcrair..
Mahoning, Medina, Portage, Summit, and Trumbull
Archaeology Region 1A - G. Michael Pratt, University of Toledo, Department
of Anthropology, Em. 10, Bancroft Avenue, Toledo. Ohio 43606,
(419) 537-2364. Counties: Erie. Huron, Lucas, Ottawa. Sanduskv.
Seneca, and Wood.
Region 2A - Alfred Lee, Cleveland Museum of Natural History,
Wade Oval, University Circle, Cleveland, Ohio 44106, (216)
231-4600. Counties: Ashtabula, Cuyahoga, Geauga, Lake.
Lorain. Medina, Portage, Summit, and Trumbull.
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Comments/84
O
'vo
NEW YORK STATE PARKS 4 RECREATION Agency Building I. Empire Stale Plaza Albany. New York 12238 Inlormalion 518 474-0456
Onn Lehman. Commtssionef
January 29, 1981
District Engineer
U.S. Army Engineer District, Buffalo
1776 Niagara Street
Buffalo, NY 14207
Attention: Regulatory Functions Branch
Dear Sir:
We would like to thank you for the opportunity to review: Draft Programmatic
Environmental Impact Statement U.S. Lake Erie Natural Gas Resource Development.
In reviewing the document we found several items which should be brought to
your consideration for preparation of the finalized document:
New York State Office of Parks and Recreation operates several Parks
in western New York State that have a long history related to gas
exploration and development. Further, existing and proposed lease
programs for these facilities are expected to make available con-
siderable quantities of natural gas.
Existing leases are operating at Allegany, Darien and Lake Erie
State Parks. I have included a short history of the Agency's program
and its objectives together with a sample copy of our lease documents
and a sample lease.
Your maps of recreational facilities should be updated to reflect
Parks and Recreation facilities operated by this Agency.
Enclosed also is a statement from the State Historic Preservation
Office, Field Service Bureau to be incorporated into your review.
Thank you for the opportunity to review this important issue.
Sincerely yours,
J . 2 . A*4j
DR. PETER J.R. BUTTNER
Director of Environmental Management
NYS Office of Parks and Recreation
Empire State Plaza, Agency One
Albany, NY 12238
(518) 473-4817
474-0445
NYPR-1
f
"3[
NYPR-2
' 2.
An Equd Oeooflurtfy Employw
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oomments/85
o
\n wt l-1
%mL
NEW YORK STATE PARKS & RECREATION Adpri- v Hu'Ul'nq 1 I'm;-ft-'jl.ilc P'.i/.i Alh.in, Ncjv Vc.rk W.ld trlnfmahun 518 474 0*56
Orin Lehman Commissioner
January 29, 1981
District Engineer
U.S. Army Engineer District, Buffalo
1776 Niagara Street
Buffalo, NY 14207
Attention: Regulatory Functions Branch
Dear Sir:
We would like to thank you for the opportunity to review: Draft Programmatic
Environmental Impact Statement U.S. Lake Erie Natural Gas Resource Development.
In reviewing the document we found several items which should be brought to
your consideration for preparation of the finalized document:
1. New York State Office of Parks and Recreation operates several Parks
in western New York State that have a long history related to gas
exploration and development. Further, existing and proposed lease
programs for these facilities are expected to make available con-
siderable quantities of natural gas.
Existing leases are operating at Allegany, Darien and Lake Erie
State Parks. I have included a short history of the Agency's program
and its objectives together with a sample copy of our lease documents
and a sample lease.
Your maps of recreational facilities should be updated to reflect
Parks and Recreation facilities operated by this Agency.
2. Enclosed also is a statement from the State Historic Preservation
Office, Field Service Bureau to be incorporated into your review.
Thank you for the opportunity to review this important issue.
Sincerely yours,
DR. PETER J.R. BUTTNER
Director of Environmental Management
NYS Office of Parks and Recreation
Empire State Plaza, Agency One
Albany, NY 12238
(518) 473-4817
474-0445
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jmments/86
Chautauqua count/
p department of planning and development
county office building mayville, new york 14757 phone 716 ¦ 753-4296
January 5, 1981
JOSEPH GERACE
County Executive
Colonel George P. Johnson
Buffalo District
Corps of Engineers
1776 Niagara St.
Buffalo, New York 14207
Re: Draft Programmatic Environmental
Impact Statement: U. S. Lake Erie
Natural Gas Resource Development
Dear Sir:
A review of the programmatic statement suggests a Herculean work effort with the
majority of general environmental issues addressed..
CCD-1 fThe major and first issue, of course, is the economic need for the gas resources
I under Lake Erie. I believe that we should allow free market conditions to dictate
l^when and if they are necessary.
CCD-2 f*There are a number of site specific issues which probably cannot be addressed in
I a document such as the one that has been presented. I assume, in reviewing the
draft document, that site specific issues will still be under scrutiny and EIS
h
I procedures.
The assumption that the three major cities on Lake Erie will be the "work ports"
for the majority of the vessels serving the gas development program is probably
correct. The majority of the Lake Erie coast communities will not see great eco-
nomic impacts or jumps in employment. However, I cannot help but believe that
during the whole process of utilizing the gas resources from under Lake Erie that
there will be an increase in traffic at small harbors used to support the system
of larger vessels and activity. What will be these demands? What additional
facilities will be needed locally? Who will be responsible for responding to
emergency conditions? What will be the local governments' responsibility in case
of emergency?
•
This latter question is asked because, based on experience along the shores of
Lake Erie and Chautauqua County, some emergency efforts on just one incidence has
seen tens of thousands of dollars in public and private volunteer time spent in
emergency efforts with people on Lake Erie. Will the gas industry, the Coast Guard
or the states in any way augment the existing emergency systems? Based on the
present pattern of coverage of the shore of Lake Erie and Chautauqua County's ex-
perience, someone must be responsible for the creation of an emergency program.
It cannot be left to impact totally on the volunteer systems which basically serve
the majority of the coastline. Even when viewing the emergency preparedness of the
County of Chautauqua, the type of equipment and/or facility needed to respond is
limited or does not exist. One incidence off the shores of Chautauqua County in
Lake Erie received national attention. Out of curiosity, this office attempted to
assign a cost to the emergency effort which took place. It should be noted that
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i.omments/87
Colonel George P. Johnson -2- January 5, 1981
we were unable to engage the assistance of federal or state agency in terms of
manpower for this effort beyond radio vectoring. Based on manpower, time, equip-
ment utilization, equipment lost, it is felt that no less than $35,000 and possibly
as much as $65,000 would have been the cost of the operation if it had been "paid
for." It would seem that within the revenues to be drawn from the specific states
that appropriate equipment and augmented manpower programs could be created so that
^emergency efforts do not become a cost to the local municipality.
'how many miles of major new transmission line will be needed to collect the gas
from the landfall sites? A review of material on hand in this office would indi-
cate that one of the proposed landfalls in Chautauqua County could possibly be
served by existing systems. Based on our files, however, the second or westerly
landfall site would probably take new pipeline construction in order to put the
proper sized lines in to serve the landfall site. This question has to be raised
along the total shoreline.
This office has just completed a review of the New York State Public Service Commis-
sion's Case 80007, Lake Erie Generation Station. Within the siting process for
this facility, was rather a detailed examination well beyond that of your program-
matic effort dealing with Lake Erie currents along the southern shore and in par-
ticular along the shores of Chautauqua County. Along with this hearing process
and found in the files of this department are periodic aerial photographs of the
shoreline of Lake Erie. All aerial photography of the offshore area of the City
of Dunkirk shows a plume from the outfall of the Dunkirk sewage treatment plant.
All photography finds this plume ranging thousands of feet from the outfall point.
Based on the aerial photography and the work done on the Lake Erie Generating Sta-
tion, we must raise the following question. Is the one-mile buffered distance
down current from the City of Dunkirk's water intake adequate distance to restrict
well construction and landfall facilities? We do not pretend to know what the
distance should be but we strongly question whether a one-mile buffer zone off of
this water intake will provide fail-safe protection of the water supply not only
for the City of Dunkirk but for its surrounding communities. We look to the City
of Dunkirk's system as the primary water system drawing water from Lake Erie for
.a large portion of the coast population of Chautauqua County.
Under the programmatic approach, the landfall sites do not seem to be a problem.
However, site specific actions will not hold to such an innocent review and it
is the assumption of this reviewer that landfall sites will be subject to an EIS
process. If this assumption is incorrect, this office reserves the right to make
further comment upon response to the question.
f It would seem appropriate that in the creation of the permitting process that be-
cause of. the unknowns, a small royalty be charged or a portion of the bid money
be placed in an emergency fund for restoration of shoreline damages or littering
caused by the offshore drilling activities. If created as a royalty fund, it
should be created in such a manner that it would become a deposit which would be
returnable to the parties concerned at the conclusion of the program. The
funds to be held in such a manner that they may be actively drawing interest, if
the royalty fund remains untapped for corrective activities, it is to be returned
to the industry. These funds to be used when it can be proven that shoreline
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comments/88
Colonel George P. Johnson -3- January 5, 1981
CCD-8 damages were caused by actions taking place on the lake associated with the dril-
ling and gas extraction process. It is recommended that the funds be at an inter-
state or federal level instead of a state level. Activities in one part of the
lake can affect shorelines in other states and there should be an opportunity for
^the easy interstate movement of these funds.
In closing, I commend the Corps of Engineers and the Environmental Protection Agency
on their efforts. I do not believe that any further comment can be made until we
are dealing with a site specific or program sponsor.
Respectfully,
John R. Luenfeman, Director
Planning and Development
JRL:mjs
Joseph Gerace, County Executive
Robert L. Barber, Chairman, County Legislature
Gregory H. Sovas, Chief, Bureau of Mineral Resources,
NYS Dept. of Environmental Conservation
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uomments/89
COUNTY OK ERIE
Department of Health
Wrsl StrciM
Eritt. IVmukvIn iini.i H»r>07
Russai D. Rooson BI4 / 454-r.iu i John J Torn
COUNIY EXECUTIVE ACTING OUSCTOR
January 6, 1981
Col. George P. Johnson
District Engineer
U. S. Army Engineer District
1776 Niagara Street
Buffaloj NY 14207
Attention Regulatory Functions Branch
Dear Colonel Johnson:
The Erie County Department of Health has reviewed the Draft Programatic
Environmental Impact Statement: U. S. Lake Erie Natural Gas Resource
Development. We request that the following be made part of the Environmental
Impact Statement relating to the subject.
Environmental problems and potential problems have developed in Erie
County due to land-based gas drilling activities. There has been a recent
increase in drilling activity in our county, an increase in environmental
complaints from local residents, and actual and/or alleged violations of the
Pennsylvania Clean Streams Law with respect to the drilling activities.
The Pennsylvania Department of Environmental Resources (DER) is currently
studying problems relating to the gas and oil industry. It is estimated by
this Department that it may be two or three years before needed laws and/or
regulations of the Pennsylvania DER concerning the gas and oil industry are
in effect.
CEH-1
CEH-2
CEH-3
With some of the gas industries present land-based problems unresolved, it
seems premature to consider offshore drilling where complex problems will be
encountered. Proper disposal of waste from onshore drill sites is presently
difficult, at best, and will be more difficult over the water. Enforcement is
relatively ineffective due to the lack, of standards, regulations and insufficient
sstaffing of environmental personnel.
r
We believe the U. S. Army Corps of Engineers, the U. S. Environmental
Protection Agency, and the Pennsylvania DER would be remiss in issuing any
I permits for offshore drilling prior to Pennsylvania developing acceptable
I enforceable regulations for such offshore drilling operations.
The Department advises against offshore drilling until the industry has
readily available proper solid waste disposal sites and proper liquid waste
I disposal sites. Also, there must be acceptable development construction and
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Comments/90
Col. George P. Johnson
Page 2
January 6, 1981
CEH-3 I production standards, adequate enforcement personnel, availability of
I transportation for enforcement personnel to and from the offshore sites,
I and proper rules and regulations are adopted by the Pennsylvania DER for the
gas and oil industry.
L8
CEH-4 f We also believe a contingency plan should be developed before any
I drilling in the lake commenses. Equipment and materials should be readily
I available to the industry to clean up any spills that occur.
The Department has specific questions, comments, and/or suggestions on
the following:
CEH-5
Page vii S.009
' It appears a regulatory task force would be necessary to assure uniform
activities. It seems this should be set up before the final E.I.S, is
published in order that the public can have input on the standards. Also,
there should be assurance that all states have adequate enforcement personnel,
equipment and regulations to control offshore drilling activities.
Page vii, S.011
What provisions will be provided or mandated to assure that there is
adequate surveillance, sampling and appropriate enforcement where infractions
are found? Will companies be required to post bonds from the day the well is
drilled until the day it is abandoned and satisfactorily plugged? Will bonds
^be required for pipelines and waste disposal areas?
Page vii. S.013(g) Disposal of Residuals
** There is concern that there is presently no known Resource Conservation
and Recovery Act (RCRA) approved disposal site in our area for the types of
waste generated. No actual drilling permits for drilling should be issued until
at least one is available that is within a reasonable distance and readily
accessible and available to all drilling companies.
Presently, there is no suitable on-land subsurface disposal well in
operation in the area. Also, presently we question if there are areas in the
county that might be readily available and suitable for on-land spray irrigation
of waste such as these, especially in view of the use of local groundwater for
drinking. He advise against issuing any permits until acceptable liquid and
solid waste sites are a reality.
CEH-8
f
Page lx, S.018
The report indicates the loss of well control would result in releases of
petroleum-related hydrocarbons for periods of up to fifteen days. How was the
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Comments/91
Col. George F. Johnson
Page 3
January 6, 1931
CEH-8
fifteen day figure arrived at? Did it take into account the possibility of
failure at the "end of the season" when wind, ice formation, etc., would
possibly lengthen the time until the site could be controlled? How would
repairs be effected (for example, if a relief well were needed) in the winter
if the lake were ice bound?
CEH-9
Pane x. S.021
Seismic active areas have been identified. The identification process
apparently was with respect to predicting damage to lines and wells with
possible subsequent environmental problems.
What is the probability of causinR or triggering earthquakes by the
removal of the natural gas and the release of pressures? What is the likely
magnitude of any earthquake(s) and the damage that may be caused? Would drilling
companies be held liable?
CEH-10
Page xi S.023
f The proposed end of the drilling season is October 31. Does this mean all
equipment will be off the lake by October 31 or does it mean drilling will
cease on October 31? Does this give adequate time to take care of any problems
(such as an uncontrolled release of hydrocarbons) before ice becomes a problem?
Should the drilling season open on the "average" ice off condition in the
spring on April 1 or should the drilling season start at the latest recorded
date of ice in our area of Lake Erie?
CEH-11
Page xil. S.031
The reaction of polyethylene glycol and chlorine should be taken into
consideration before any approval is given by the Corps rather than vice versa,
as it seems the intent of the requirements of the impact statement to look at
the issues before approval rather than giving approval and then looking at
potential problems.
CEH-12
(
Pane 1-83 (1.110)
This Department has information that brines may also contain lead, cadmium
and copper. Possibly other metals or materials are in the brines, if so, these
constituents and their ultimate disposal should be adequately addressed.
CEH-13
Par;e 1-84 (1.1161
We would recommend that the industry prove whether drilling fluids are
hazardous or not. If components of fluids are unavailable or inadequately
characerized, then they should not be permitted to be used. For example, there
appears to be little information on biocides that may be used to maintain
porosity. It would seem that the Corps would be remiss not to know exactly
-------
comments/92
Col. George P. Johnson
Page 4
January 6, 1981
CEH-13
what Is in all the fluids and Che probable or possible adverse environmental
impact(s) of using them. It would seem these issues should be addressed and
resolved before the Corps makes any judgement on the question of offshore
drilling.
Page 1-87
CEH-14 [
b
It is not realistic to expect that waste will, as a matter of policy,
hauled 150 miles to an undefined landfill area south of the lake.
be
CEH-15
Page 1-93 (1.135)
If pipes are laid on the lakebed in waters of 30 feet deep or more, how
securely will they be attached to the bottom? Hill gill net boats, for example,
be likely to rupture or crack the lines when the net anchors are pulled up?
Will pipes and/or wellheads interfere with the commercial dredging of sand
and gravel that presently takes place in Lake Erie? Possible conflicts
between the dredging industry, fishing industry and the gas well industry
should be addressed and resolved before a final decision is made to issue
permits.
Page 3-16 (3.057)
CEH-16
The last sentence in the paragraph reads, "In Pennsylvania, it is doubtful
that commercial fishing still takes place." The Corps is advised to check
with the Pennsylvania Fish Commission on this statement. Commercial fishing
should have been included in the Draft Environmental Impact Statement (DEIS).
The statement in the DEIS regarding the status of commercial fishing in
Pennsylvania does jeopardize the creditability, depth and accuracy of the
entire statement.
CEH-17
Under Section C, there is insufficient information on the impact of
adverse discharges on fish and wildlife (what is the worst anticipated senario
with respect to fish life - ducks, seagulls, etc.; winter, spring, summer,
fall). What is the worst anticipated affect on the multi-million dollar tourist
^industry in Erie County?
CEH-18f
CEH-I9P
l
There is insufficient information on stimulation fluids, surfactants,
etc. Specifically, what are all chemicals used and what are their concentrations?
On page C-7, what would the pH be at the point of release? What would it
be at 0.5 miles? How fast would this happen? How long would it take to get
back to normal? How many fish might it kill under the worst possible senario?
-------
Comments/93
Col. George P. Johnson
Page S
January 6, 1981
CEH-20
Also, we wish to note Chat a local company disposal of liquid wastes, In
prior years, through the use of a deep well injection procedure. An eruption
of the disposed wastes occurred previously and there is a question about the
possibility of penetrating the reservoir and releasing these wastes during
drilling or test boring activities. Has this been explored and are provisions
being made to prevent such an occurrance? If so, what are they?
This Department realizes the need for natural gas and appreciates the
complex problems facing the industry; however, until such time as all
environmental problems are adequately addressed and resolved, we do not
advocate issuing permits for dilling in Lake Erie.
Very truly yours,
Charles F. Vrenna, Director
Water Quality and Land Protection
CFV/RJW/cas
-------
i.omments/94
RuSStuD Robbon
axwrv txEcunvt
COUNTY Of ERIE
Department of Health
f)0(> Wt'sl Snuiml St'rrrI
Kric. Pinntsv K iiiij.i llif>l)7
HI-I ' -ir.-t-.-idl |
John J. Tom
ACTING CHBfCIOl!
January 8, 1981
Col. George F. Johnson
District Engineer
U. S. Army Engineer District
1776 Niagara Street
Buffalo, NY 14207
Attention Regulatory Functions Branch
Dear Colonel Johnson:
On January 6, 1981, the Erie County Department of Health responded to
the Draft Programatic Environmental Impact Statement: U. S. Lake Erie Natural
Gas Resource Development.
Subsequent to our mailing our comments, we noted a typograpical error
on the fifth page of our comments and are requesting that you correct our
response.
The first sentence on the top of the page reads in part: "a local
company disposal of liquid waste ..." The sentence should be corrected to
^ead: "a local company disposed of liquid wastes. . ."
Should you have any questions concerning this matter, please contact
this office.
Thank you for your kind attention.
Very truly yours
Charles F. Vrenna, Director
Water Quality & Land Protection
CFV/RJW/cas
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Comments/95
ALLEGANY COUNTY
CATTARAUGUS COUNTY
CHAUTAUQUA COUNTY
SOUTHERN TIER WEST
REGIONAL PLANNING AND DEVELOPMENT BOARD
41 MAIN STREET
Marden E. Cobb, Chairman
John W. Hasper, Vice Chairman
Don B. Winship, Secretary
SALAMANCA, NEW YORK 14779
PHONE 7U-945-5301
Hoy B. Campbell, Director
945-5303
945-5538
8 January 1981
STW-1
STW-2
Col. George P. Johnson, District Engineer
Buffalo District, Corps of Engineers
Attn: Regulatory Functions Branch
1776 Niagara Street
Buffalo, New York 14207
Dear Col. Johnson:
I have just completed a review of the Draft Programmatic Environmental Impact Statement
entitled "U.S. Lake Erie Natural Gas Resource Development" and have the following
comments.
"The DEIS is general in scope and not site specific, the reasons for which are explained
in the document. The question thus arises as to what opportunity for comment and input
will be given the public and interested agencies and organizations when the Corps of
Engineers receives a site specific permit request. While I have little disagreement
with the contents of the DEIS (except as noted below), the future of public involvement
Jn the permit process of all parties involved should be documented.
'"My second comment relates to the on-land disposal of solid (hazardous) wastes. New
regulations from both the State and Federal governments have made the disposal of such
wastes difficult. This is especially true of recent New York State actions relating
to the Siting of Industrial Hazardous Waste Facilities. In addition to the actual
disposal of the wastes, the transport of the wastes to an approved site must be ad-
dressed in more detail.
I hope these comments are useful to your effort and should further information be
required please feel free to contact me.
Sincerely yours,
LINDLEY V. PRYOR, AICP
Chief - Physical Planning
LVP/ces
cc: Mr. Gregory H. Sovas
Chief - Bureau of Mineral Resources
NYS DEC
50 Wolf Road
Albany, New York 12233
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v,omments/96
"• \k
-------
comments/97
Colonel George P. Johnson Page 2 Steven M. Johnson
January 9, 1981
CCH-4
This Department would be interested in reviewing further environmental
impact information on specific well locations. Thank you for the opportunity
sto coranent on this draft report.
Very truly yours,
Steven M. Johnson, P.E., Director
Environmental Health Services
SMJ/jlr
cc: Mr, Gregory H. Sovas, Chief, Bureau of Mineral Resources
-------
„omments/98
COUNTY OF ERIE
Office of the County Executive
Erie, Pennsylvania 16501'
Russai D. IJOBSON - AREA COOS 814
couNrv executive J a n u a ry 9 , 1981 telephone aso^ssi
Colonel George P. Johnson
District Engineer
U. S. Army Engineer District
1776 Niagara Street
Buffalo, New York 14207
Dear Colonel Johnson:
The County is concerned that there be a thorouqh assessment
of the environmental impact on drilling for natural gas in
Lake Erie. The citizens of the County are sensitive to the
need to protect this vital, fresh-water resource. Over the
past few years, there has been an extensive development of
on-shore gas resources in Erie County. The County has re-
ceived numerous complaints from the citizens about actual
and alleged pollution of nearby streams and the groundwater
serving some individuals, as well as the destruction of
vegetation on private property. At the present time, neither
the County Health Department or Pennsylvania Department of
Environmental Resources has the necessary rules, regulations,
standards, personnel or equipment to control such abuses.
It is vital that proper safeguards be developed to ensure
that Lake Erie, as a fresh-water resource, be protected. I
would recommend that before development of this natural gas
resource is undertaken the following steps be required to
^ensure the public:
(
1. Adequate rules, regulations and standards to
control off-shore drilling be adopted by
Pennsylvani a.
2. That a mechanism be established to provide
that a certain percentage of royalties from
the natural gas revenues be required to be
set aside to be used exclusively for pro-
viding the equipment and personnel to monitor
the off-shore drilling operations.
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-omments/99
Colonel George P. Johnson -2- January 9, 1981
As the chief elected official in Erie County, I have stressed
the quality of life for the citizens. The Corps-, in its de-
liberations, should do its utmost so that the quality of life
is not compromised.
Very sincerely,
Russell D. Robison
County Executive
RDR/ej
-------
-^inments/100
County of Erie
EDWARD J. RUTKOWSKI
COUNTY EXECUTIVE
PHONE: 716-M6-8500
January 12, 1981
CEXN-1
Colonel George P. Johnson
Buffalo District
U.S. Army Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Dear Colonel Johnson:
Thank you for submitting for our review the Draft
Programmatic Environmental Impact Statement concerning U.S. Lake
Erie Natural Gas Resource Development. Lake Erie represents an
important natural resource to the residents of -Ehrie County. In
addition to serving as our major-water supply source, the Lake
provides invaluable opportunities for recreation, economic develop-
ment and aesthetic enjoyment.
Support for commencement of gas drilling can only be
given if proper safeguards are provided to protect the Lake. This
is especially important to Erie County as our location guarantees
that contamination from any of the proposed drilling areas will
affect our drinking water supply. The Draft Environmental Impact
Statement as submitted does not adequately address the question
of appropriate safeguards. A final Environmental Impact Statement
should address the following concerns:
1) The draft report is based on a reference program
approach which assumes that a certain amount of drilling will
occur in the Lake during a specific time period. The report also
assumes that such drilling will be regulated by Ohio, Pennslyvania
and New York through new state legislation which incorporates the
regulatory guidelines identified in the draft document. Since
ERIE COUNTY OFFICE BUILDING. 95 FRANKLIN STREET, BUFFALO. NEW YORK 14202
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-jmments/101
Colonel George P. Johnson
Page 2
January 12, 1981
CEXN-1
CEXN-2
the entire report is based on the above assumption, serious concerns
can be raised should the proposed guidelines not be enacted by each
state. The validity of the entire report can be questioned due
to this, issue. It should be made explicit that the Federal Govern-
ment will permit drilling only in those states that adopt uniform
regulations. If this is not done, a situation similar, to that
caused by migration of acid rain may arise.
2) Impacts which may occur during each individual drilling
operation cannot be adequately examined using the programmatic
approach. Erie County is very concerned that comprehensive environ-
mental analysis occur prior to each specific drilling operation
which examine impacts to water quality, shoreline erosion, waste
^disposal sites, and fish habitat areas.
CEXN-3 f 3) A portion of the royalty fund each state will receive
I from gas drilling should be earmarked for local cleanup operations
lin the event of any emergency occurring due to drilling operations.
CEXN-4[ In addition, since the risk to a major resource of this
I area is so great, the question of need for Lake Erie natural gas
lin the regional and national fuel supply system' should be documented.
|l don't feel that this has been adequately documented.
CEXN-5
' Due to the above concerns and the critical need for public
involvement in the Lake Erie gas drilling issue, Erie County
officially requests that a public hearing be held in the near future
Relative to the draft report.
Once again, thank you for the opportunity to review and
comment on the Draft Environmental Impact Statement.
Very truly yours.
EDWARD J- RU^KOWSKI
EDWARD J- Wfo
County Executive
EJR:lt
Attachment
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,mments/102
January 12, 1981
ERIE COUNTY CONCERNS REGARDING
THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
U.S. LAKE ERIE NATURAL GAS RESOURCE DEVELOPMENT
Erie County, New York, benefits from being located adjacent
to Lake Erie in a variety of ways. In addition to serving as the
major water supply source for Erie County, the Lake also provides
invaluable opportunities for recreation, economic development and
aesthetic enjoyment. Any activity which has the potential of harming
this freshwater resource is of great and utmost concern to Erie County.
With this in mind, the following concerns are being submitted relative
to the Draft Environmental Impact Statement prepared by the U.S. Army
Corps of Engineers and the U.S. Environmental Protection Agency con-
cerning U.S. Lake Erie Natural Gas Resource Development. It is
requested that these be given full consideration during the draft
revision process.
1. A major concern pertains to the need for a clearer indication
within the draft report relative to gas drilling's potential impact
to the County's drinking water supply. Lake Erie is the water supply
source for most of the 1,013,300 residents within the County and must
^be protected from any potential adverse impacts.
"2. It must be stressed that Lake Erie gas drilling represents a
severe environmental risk to Erie County without any guaranteed
benefit. The gas produced will be placed within New York State
pipelines and distributed throughout New York State, yet any environ-
mental impacts will be borne solely by Erie and Chautauqua Counties.
This is of great concern. It is therefore critical that prior to any
drilling operation the issue of immediate and future need for Lake
Erie gas within the regional and national fuel supply system be
determined through a comprehensive study. The question remains why
assume any risk, if there is not a current demonstrated need for
Lake Erie gas. An argument for Lake Erie gas drilling is that it
will provide a degree of energy security in the event of another gas
curtailment such as occurred in 1977. The fact is that at the present
time and for the foreseeable future, there is an over-abundance of
natural gas available. This situation can be attributed to conserva-
tion efforts, on-going price deregulation which encourages new
exploration and the development of unconventional gas sources.
Furthermore, alternative sources such as land drilling, methane pro-
duction from solid waste, hydrogen gas, and other resources can equal
^ the lake production at less environmental risk.
3. Erie County has several concerns regarding the overall approach
taken by the U.S. Army Corps of Engineers and the U.S. Environmental
Protection Agency in preparing the draft Environmental Impact State-
ment. These are outlined as follows:
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i.omments/103
-2-
CEXN-8
CEXN-9
CEXN-10
CEXN-11
^ a. Although the reference program approach is justified
"due to the current lack of specific drilling or lease
activity, this should not preclude the need for more
specific impact statements if so warranted, during the
actual federal and state permit issuing process. Erie
County requests assurance that the Reference Program
method will not become a blanket environmental approval
when all future federal government permits are sought by
drilling operators.
b. The draft Environmental Impact Statement assumes that
the proposed drilling guidelines outlined in Appendix D
of the report will be enacted by Ohio, Pennsylvania and
New York. This would provide a uniform and comprehensive
set of standards applicable to all drilling activity.
Since many of the measures suggested in the report for
mitigating potential environmental impacts are dependent
on enactment and subsequent enforcement of the proposed
guidelines noted in Appendix D by each State, a serious
concern can be raised. In the event the proposed guidelines
are not enacted, it can be assumed that many of the miti-
gating measures noted in the Environmental Impact Statement
would not be carried out to an adequate degree. Thus, the
conclusions drawn in the report would no longer be applicable.
Erie County has serious concerns regarding this issue and re-
quests that all federal permits for drilling in Lake Erie be
prohibited until uniform and acceptable guidelines based on
those proposed in the Environmental Impact Statement are
collectively enacted by the States of Ohio, Pennsylvania
and New York. Sufficient time for public review of the
guidelines must also be provided.
4. Erie County has the following concerns regarding specific points
raised in the draft Environmental Impact Statement:
a. The draft Environmental Impact Statement and accompanying
proposed drilling guidelines do not prohibit pipeline con-
struction from occurring in sensitive public and natural areas.
It is suggested that pipelines be prohibited from such areas
including critical erosion hazard areas, coastal wetlands,
significant fish spawning habitats, and any others deemed
appropriate. These areas should be located and mapped by an
appropriate State agency.
b. The draft Environmental Impact Statement notes that approxi-
mately 250 workers would move into the Buffalo area during
peak employment in 1985. It is also noted that total direct,
indirect and induced employment in the Erie County area in 1985
could reach 1236. Such figures seem high based on socio-
economic impact studies prepared for other large scale con-
struction projects. A special concern pertains to the induced
employment figure estimated at 988. The report does not clearly
define induced employment nor provide adequate background
documentation. It is our concern that these employment figures
be fully documented in order to provide a clear understanding
of the potential socio-economic impact to the County.
-------
.mments/104
-3-
CEXN-12
CEXN-13
c. The draft Environmental Impact Statement indicates that
drilling activity will result in the creation of wastes re-
quiring disposal in both secure and non-secure landfills.
Erie County currently is experiencing a shortage of landfill
sites and is very concerned about the creation of more waste
products from the drilling activity.
X
5. Assuming that there is a demonstrated need and benefit for
the area from Lake Erie Gas Drilling the County believes that pro-
visions for coping with an emergency should be in place now prior to
leasing. Due to Erie County's location" at the end of the lake, local
governments and industry have continuously received the brunt of lake
pollution and contamination increasing local costs for water purifica-
tion and treatment. Continued responsibility should not fall on local
government. We suggest that a portion of the money received by the
States for leases be placed in an escrow account to be used in
emergencies caused by or related to the Lake drilling program. This
fund could be redistributed to the States when the gas is depleted.
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urniments/105
PUBLIC MEETING STATEMENT
Public Meeting Topic;"
DRAFT ENVIRONMENTAL IMPACT STATEMENT - U.S. LAKE ERIE
NATURAL GAS RESOURCE DEVELOPMENT (December, 1980) prepared
by U.S. Army Corps of Engineers and U.S. Environmental
Protection Agency.
Public Meeting Location:
Buffalo State College
1300 Elmwood Avenue
Buffalo, New York
Statement Presented by: EJwc.rd J. Rutkowski,
Erie County Executive
Date: February 11, 1981
Time: 7:30 P.M.
-------
-oraments/106
-1-
On behalf of Erie County, New York, I Wish to thank the
U.S. Army Corps of Engineers for holding tonight's public meeting.
The issue of Lake Erie gas drilling is an important one and requires
that full opportunity be provided for government and private citizen
involvement.
Prior to outlining our concerns with the draft Environmental
Impact Statement, I feel it is appropriate to stress the importance
of Lake Erie to our area.
The Lake represents a valuable natural resource to Erie County
by providing a fresh water supply source for most of the County's
1,013,300 residents, as well as to the majority of industrial and
commercial establishments throughout our area. The Lake also pro-
vides valuable opportunities for fishing and swimming which are
immediately accessible to all residents of Erie County.
In recent years, Erie County and its local governments have
recognized the need to improve and maintain the Lake's water quality
so that the above mentioned benefits continue to^contribute to the
high quality of life enjoyed by all our residents. During the 1970's
approximately $253 mil. of public funds have been invested in con-
structing efficient sewage treatment plants along the Erie
County shoreline. This certainly reflects the importance Erie County
places on improving and maintaining the water quality of Lake Erie.
The Lake's value to this area, as well as our interest in
protecting the public investment made in improving its quality
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v.omments/107
-2-
warrant our close examination of the draft Programmatic
Environmental Impact Statement. A further reason for our
strong interest is the location of Erie County within the
Great Lakes Basin.
Since the upper Lakes eventually flow through the
Niagara River-, it is likely that any major spills or gas
leaks occurring in the western and central parts of Lake
Erie would cause serious environmental problems along the
Erie County shore.
With these points in mind, I wish to outline the following
concerns regarding the draft Environmental Impact Statement.
1. The report should provide a clearer indication regarding
gas dilling's potential impact to the County's drinking
water supply. The potential for accidents will be present
during any gas drilling operation and it is very important to
outline in comprehensive terms what the risks will be as well
as their accompanying impacts.
"2. The draft report is based on a reference program approach
which assumes that a certain amount of drilling will occur
in the Lake during a specified time period. The report also
assumes that such drilling will be regulated by Ohio,
Pennsylvania and New York through new state legislation which
incorporates the regulatory guidelines identified in the draft
document. Since the entire report is based on the above,
assumption, serious concerns can be raised should the proposed
inos rrit- be enasted bv each state. The validity of the
¦»n +
-------
-omments/108
-3-
drilling only in those states that adopt uniform regulations.
If this is not done, a situation similar to that caused by
migration of acid rain may arise.
Impacts which may occur during each individual drilling
operation cannot be adequately examined using the reference
program approach. Erie County is very concerned that a
comprehensive environmental analysis occur prior to each
specific drilling operation.
A portion of the royalty fund each state will receive from
gae rlrSllino should hp earmarked for local cleanup activities
in the event of any emergency occurring due to drilling
operations. Responsibility for clean-up operations roust not
fall on local governments.
5. 'Although various sources have indicated that Canada has
permitted Lake Erie gas drilling for many years without any
major environmental impacts, I wish to raise an important
point regarding .this issue.
The number of major port facilities and population density
along the U.S. shoreline of Lake Erie in comparison to the
Canadian side would indicate that the volume of commercial
navigation and recreation boating occurring in U.S. waters is
greater than that taking place within the Canadian section of
the Lake. This would serve to increase the potential for
accidents between gas drilling and commercial/recreation
boating activity. It is hoped that the final environmental
impact statement would clearly outline the potential for such
accidents, as well as the appropriate measures wM ch are
necessary to prevent their nrnirrpnpp.
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-jmments/109
- 4 -
It must be stressed that Lake Erie gas drilling represents
a potential environmental risk to Erie County without any
proven benefit. The gas produced will be placed within
New York State pipelines and distributed throughout New
York State, yet any environmental impacts will be borne
solely by Erie and Chautauqua Counties. This is of great
concern. It is therefore, critical that prior to any
drilling operation the issue of immediate and future need
for Lake Erie gas within the regional and national fuel
supply system be determined through a comprehensive study.
The study should also identify the specific economic benefits
to Erie County. Some of the benefits which should be examined
include the potential for guaranteed energy supply source to
local users, potential spin off industrial investment, and
natural gas pricing benefits for Erie County users.
In conclusion, Erie County recognizes the potential value and
importance of Lake Erie gas to the regional and local energy supply
system, yet we are also very aware of the value of Lake Erie as our
major fresh water supply source. It is our concern that the pursuit
of natural gas occur in an environmentally sound manner without
jeopardizing the Lake's function as a valuable natural resource.
Therefore, if regulatory safeguards are enacted which minimize the
risk to our fresh water supply system Erie County will support Lake
Erie gas drilling.
Once again, thank you for the opportunity to present our
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-omments/llO
-5-
concerns and ve look forward to receiving the Final Environmental
Impact Statement in the very near future.
Respectfully submitted,
EDWARD J. RUTKOWSKI
-------
wOmments/lll
ERIE & NIAGARA COUNTIES
Lfet. Jf. - htr.rr*/. '/*
REGIONAL PLANNING BOARD
January 16, 1981
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.jmments/112
Erie and Niagara Counties Regional Planning Board
Review of
Draft Programmatic Environmental Impact Statement
U.S. Lake Erie Natural Gas Resource Development
Prepared by
Phillip M. Atkin, Senior Planner
Henry C. Jawor, P. E., Sanitary Engineer
David A. Stebbins, Assistant Planner
Gregory A. Stubbs, Assistant Environmental Quality Scientist
JANUARY 1981
Erie and Niagara Counties Regional Planning Board
3103 Sheridan Drive
Amherst, NY 14226
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wOmments/113
The Draft Programmatic Environmental Impact Statement: U.S. Lake Erie
Natural Gas Resource Development prepared by the U.S. Army Corps of Engi-
neers and the U.S. Environmental Protection Agency was reviewed by ENCRPB
staff in an effort to identify possible impacts upon adopted regional plans and the
relationship to adopted regional goals and objectives with respect to the develop-
ment of natural gas in the U.S. waters of Lake Erie.
The major concern associated with gas development in Lake Erie is the potential
environmental impacts associated with the drilling processes. Since Lake Erie
is the principle source of potable water for this and other regions, impacts on
water quality are of particular importance. The primary purpose of the Pro-
grammatic Environmental Impact Statement (EIS) is to determine whether natural
gas development in Lake Erie is environmentally acceptable. A number of possible
irripacts on water quality associated with construction activities, routine operation,
and accidents have been identified in the EIS.
I. Relationship of the EIS to Regional Planning Board Plans, Goals, Objectives
and Programs
A. 203 Water Quality Management Program:
Section 208 of the Federal Water Pollution Control Act of 1972 provided
local areas the opportunity to plan and manage a comprehensive water quality
management program. State governors were given the power to designate
areas within their states that have substantial water quality problems. The
Governor of New York State designated Erie and Niagara Counties as a region
in which a 208 program would be developed. The Erie and Niagara Counties
Regional Planning Board was designated the agency to conduct the 208 program.
^ Natural Gas development in Lake Erie is inconsistent with the 208 program
goal of water quality which provides for the protection and propagation of fish,
shellfish, and wildlife, and provides for recreation in and on the water to be
achieved by July 1, 1983, and the ultimate goal of eliminating the discharge
of pollutants into navigable water by 1985.
B. Adopted Regional Water Supply Plan and Program
J Lake Erie is the source of drinking water for 90% of the population of this
I region.. The potential development of gas resources in Lake Erie introduces a
| new source of additional pollutants to the Lake. Additional pollutants could
I
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wOmments/114
ENC-2
ENC-3
affect the quality of the raw drinking water supply. Elevated concentrations of
hydrocarbons in potable water supplies may present a health hazard. The
release of the 0.03 percent hexane-plus fraction to the water column from
natural gas losses to Lake Erie thus represents a concern since some of these
compounds are highly soluble, possible carcinogenic, and impart a taste and
odor to water. These compounds could elevate concentrations above normal
background levels presently in the Lake and thus have an impact upon potable
waters. Chlorination of these hydrocarbons would compound the issue because
fcof the production of as yet unknown halogenated projects. (Argonne 1978)
There is no treatment available at the water purification facilities for con-
trol of total dissolved solids. Any increase in total dissolved solids caused by
drilling activities would thus be passed through the facilities untreated (personal
communications (1978) with Walshuch, Jaworski, Jefferies, Pizzi, Jacquel, and
O'Connor). (From Argonne 1978)
ENC-4
Resuspension of sediments and increased turbidity enables the environment
to support increased populations of microorganisms altering dissolved oxygen,
pH, and other water characteristics. Increased turbidity and restoration of
microorganisms to the water column may affect a rise in bacterial counts in the
water. (Water Quality Criteria EPA 1973) Degradation of the raw water
supply from gas development may increase the level and cost of water treatment
and increase health risks. Additional data on drilling discharge characteristics
is necessary to more adequately assess water treatment capabilities. There is
a need for the development of standardized procedures by drilling operators to
be used at water treatment facilities in the event a mishap releasing unaccept-
able levels of contaminants to offshore drilling activities occurs. (Argonne
1978)
ENC-5
C. Adopted Regional Sanitary Sewerage Plan and Program and Adopted
Regional Storm Drainage Plan and Program
Gas development in Lake Erie does not directly impact on these plans and
programs. However, the ENCRPB adopted Sanitary Sewerage Plan and Program
was developed to reduce the discharge of pollutants to regional surface waters
thereby improving the quality of the Lake and regional waters. The ENCRPB
adopted Regional Storm Drainage Plan and Program to a lesser extent also
improves the quality of surface waters through control of drainage and runoff.
A large amount of capital investment and effort have been committed to improv-
ing the quality of the lake and regional waters. The potential development of
natural gas in Lake Erie with the additional pollutants and the potential adverse
^affects on water quality, is counter productive to these plans and programs.
ENC-6
r.
Land Use
1. Gas development in Lake Erie would introduce new industrial land uses
into the coastal zone. Due to the hypothetical nature of the gas development, it
2
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vomments/115
program, it is not clear which specific existing land areas will be affected,
however, since the vast majority of the coastal zone is used for recreation,
residential or public uses, it is assumed that the introduction of the new
industrial land will conflict with many existing land uses.
2. The industrial facilities that will be developed through the gas develop-
ment program will likely cause deleterious long term intrusion into the coastal
zone. Current land use patterns will be disrupted, and current land use
development trends which tend towards non-industrial, environmentally sound
projects will likely be cut back.
3. The introduction of drilling rigs into the visual plane of land users
along the shoreline is likely to diminish the aesthetic appeal of their property
and consequently the present value of land.
4. The introduction of new industrial facilities is likely to diminish the
value of land and structures in the vicinity of the proposed facilities.
5. The potential introduction of hazardous wastes, and treatment facilities
along the shoreline near pipellines will likely have severe affects on the market
value of existing properties along the shoreline.
6. Through the gas development program, potential introduction of
hazardous wastes, and aesthetic intrusions into the visual plane of the shoreline
will likely have negative impacts on tourism, recreational industries, and sport
fishing.
7. Accidents, which are inevitable under even the highly environmentally
conscious program, will have negative short term affects on recreational,
commercial, residential and public land uses as well as potential long term
affects on the viability of recreational and commercial (tourist related)
industries.
E. New York State Coastal Zone Management Program
The Statewide Coastal Zone Management Program, although not yet officially
adopted, is a useful reference document for planning concerns in coastal areas.
The draft New York State Coastal Management Program identified eleven
general issues of concern throughout the state's coastal areas. Of direct
relationship to the proposed U.S. Lake Erie Natural Gas Resource Development
are the following issues:
1. Aesthetics
2. Air Qual ity
3. Economic Development
4. Energy Development
5. Fish and Wildlife
6. Public access, and
-------
.omments/116
7. Recreation, and
8. Water Resources.
In particular, the issue of energy development, as described in the draft
Statewide Coastal Management Report {March, 1979) identifies several concerns
which must be addressed before any activity begins:
' One issue surrounding the development of natural gas in Lake Erie is the
potential damage to the lake's biota and water quality. Drilling operations and
the placement of gas pipelines underwater would result in increased, but local-
ized turbidity due to disposal of drilling muds and disturbance of bottom
materials. These operations would have temporary adverse effects on benthic
organisms. Mobile organisms such as fish would be able to avoid the area and
thus any harmful effects. Damaging impacts would result if construction opera-
tions stirred up toxic wastes which were previously dumped in the Lake. Over-
all, it appears that drilling activities may have only minor and temporary
effects.
A second issue centers upon the possibility of accidental oil and gas spills.
It is generally accepted by geologists that the changes of finding oil under the
Lake are very small. If any oil is found, state regulations and law require
that the well be permanently capped. As for natural gas, the extremely high
pressures associated with well blowouts are not expected to be encountered in
Lake Erie. If a leak does occur, the gas would simply bubble to the surface
and disperse. A large leakage of gas could ignite and burn until stopped, but
^such an occurrence would cause minimal environmental damage.
Proposed state regulations would prohibit development within half a mile
of the shoreline and half a mile of any public water supply intakes. This dis-
tance seems adequate to protect beach areas and water supplies from turbidity
problems. If these and other environmental and public safety concerns are
satisfactorily addressed, there is a moderate to high probability that natural
gas production in Lake Erie will be underway within the next five to fifteen
years.
Additional concerns not mentioned in the draft report relate to natural gas
pipeline land-fall areas and on-shore processing facilities. It is important
that these facilities be located in environmentally acceptable areas and so as
not to preclude development of on-shore areas for other uses.
With regard to the other coastal management issues mentioned above:
t
1. Aesthetics: Aesthetic considerations should be incorporated in public
and private planning and development related to gas drilling and collection
operations.
2. Air Quality: State and national air quality standards must be main-
tained.
4
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_omments/117
ENC-15 3. Economic Development: Encourage development where geological,
topographical and other environmental considerations are favorable.
4. Fish and Wildlife: Significant coastal fish and wildlife habitats should
be preserved and protected from contamination due to the introduction of toxic
substances and other pollutants.
5. Public Access: Increase opportunities for physical and visual access
to the coastline-at-large, consistent with natural resource protection and pro-
tection of private property rights.
6. Recreation: Prevent incompatible development in areas immediately
adjacent to recreational resources.
7. Water Quality: The State's water resources are recognized as one
of its major assets; water quality management requirements developed under
or pursuant to the Federal Water Pollution Control Act (FWPCA), as amended,
would be a water pollution control requirement applicable under the draft
^Coastal Management Program.
The draft Coastal Management Program has also identified a number of
Geographic Areas of Particular Concern (GAPC) along the Lake Erie coastline.
By designating areas as GAPC's, the Coastal Management Program has
assigned priority to these critical areas. The following GAPC's have been
identified:
ENC-16
1. Buffalo Outer Harbor
2. Niagara River Offshore of City of Buffalo
3. Buffalo Inner Harbor
4. Bethlehem Steel Diked Disposal area
5. Seneca Shoals
6. Woodlawn Beach
7. Eighteenmile Creek
8. Wendt Beach
9. Evangola State Park
Of particular significance is the Seneca Shoals GAPC. This is located
(see attached Newsletter) approximately 3 miles offshore from the Town of
Hamburg. It is comprised of a reef 12 to 16 feet in depth and is a major fish
congregating area, a prolific fishing ground, and a spawning area. The
management objective is to preserve and protect the existing fisheries habitat.
This GAPC would be the most likely to be impacted by U.S. Lake Erie Natural
Gas Resource Development and therefore special consideration should be
given this area.
*
Summary: The land and water areas of the coastal zone are special and signi-
ficant natural resources and special consideration should be given these areas
5
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nomments/118
in balancing the need for commercial and industrial development and the need
to preserve and enhance this resource for future generations. The coastal
area as a whole (land and water) is a more finite and critical resource than
the natural gas underlying Lake Erie, and therefore, every effort should be
made to protect it.
ENC-17
II. ENCRPB Adopted Regional Utilities Goals and Objectives
Goal and Objective 1: To improve the quality of treatment in public water and
sewer systems in the region.
a) By protecting and improving primary sources of fresh water supply.
*
Natural gas development program will have a definite effect on water
quality. This effect could be significant. But even if determined to be insig-
nificant the impact is still negative. A negative impact regardless of its
significance or insignificance is contrary to the protection and improvement
of the primary source of fresh water supply and thus inconsistent with Goal
and Objective 1.
Goal and Objective 4: To provide for the protection and propagation of fish,
shellfish, and wildlife and provide for recreation in and on the area waters.
Fish habitat, carrying capacity and productivity continue to be impaired
by the effects of cumulative impacts by man on the environment. Natural gas
development has a number of potential adverse effects on aquatic biota:
ENC-18
ENC-19
1. release of toxic materials directly and indirectly having biological
impact; contamination of Great Lakes water and biota by toxic and hazardous
substances has the potential to undermine many if not all of the fishery
improvements attained to date.
2. disruption of aquatic habitats and spawning areas; and
3. resuspension of sediments which can adversely affect fish and fish
^food populations.
Suspended materials also affect water quality which in turn directly affects
the recreational and aesthetic value. Increases in turbidity of water due to
modification of the water-body bed are subjectively regarded by many people
as pollution and so thereby reduce aesthetic enjoyment. Substantial degrada-
tion of water quality presents a health hazard and prohibits recreational use
and possibly consumption of fish from those waters. Gas development in Lake
Erie would not enhance recreational use or the protection and propagation of
fish, shellfish, and wildlife.
6
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Comments/119
Goal and Objective 5: To restore and maintain the chemical, physical, and
gsological integrity of the regional waters.
Sediment resuspehsion is associated with several phases of the gas
development program. The composition and concentrations of suspended
particles in surface waters are important because of their effects on light
penetration, temperature, solubility products, and aquatic life. (EPA Water
Criteria). Resuspension of sediment containing contaminants may have the
most far reaching effect, since resuspension may reintroduce potentially
toxic substances to the water column and enhance their availability to the
biota. Based cn the size of rigs currently in service in Canadian waters of
Lake Erie, the bottom disturbed by a jack-up rig would be approximately
7000 sq. ft. Additional resuspension will occur during other routine opera-
tions and pipe line installation though not to the same extent. Impacts from
sediment resuspension during siting and drilling should be further considered.
^(Argonne 1978)
*
Releases of materials during routine operations, well stimulation and
accidents can have an adverse impact on water quality. Drill cuttings and
bentonite clays from open cycle surface hole drilling have low solubility and
are basically chemically inert, but the introduction of these suspended solids
form a turbidity plume, which has potential mechanical and physical biological
impacts. Closed cycle drilling discharges are small and include drill cuttings
and associated drilling muds and mud additives, oils, lubricants, and drilling
fluids. The discharges are minimal but at present there is insufficient data
to assess the environmental impact of the discharge of cuttings and contami-
nants from closed-cycle drilling. (Argonne) Methane and liquid hydrocarbon
releases from routine drilling operations are insignificant but do create an
additional oxygen demand. Discharge of well fracturing material from well
stimulation present a water quality problem. Bioassays conducted indicate
some of these materials to be acutely toxic and indicate the potential for toxic
conditions to occur. (Argonne) Descriptions of accidents were included in
the Argonne study and in the Draft EIS using worst case modeling. The
possible accidents are many and the severity variable allowing for wide
ranging environmental impact making assessment difficult. A greater detailed
knowledge of the chemical, composition of released materials and physical
characteristics of the Lake and atmosphere is needed before the environmental
consequences of potential accidents can be evaluated (Argonne 1978). The
associated impacts all have a negative effect on the chemical, physical, and
biological integrity of the Lake and represent a degradation rather than a
restoration and maintenance of regional waters. Natural gas development
is clearly inconsistent with goal 5.
ENC-22
r
Utilities Goal and Objective 7: To assure adequate control of pollutants
entering regional waters.
Development of gas in Lake Erie will permit additional discharge of
7
-------
„omments/12Q
ENC-22
I pollutants to the lake. Allowa ice of additional pollutants when not necessary
I or justified is inconsistent with adequately controlling pollutants entering Lake
Erie and downstream waters.
111. Economic Analysis
J
ENC-23 Based on the ENCRPB staff review of the Argonne National Laboratory study's
projected potential Lake Erie natural gas resource and the economic overview
and economic issues sections, there appears to be no significant economic
justification to warrant the proposed development. The potential for adverse
environmental impacts outweigh the economic considerations.
Basis for Conclusion: Total estimated production over 22 years is approxi-
mately 533-888 BCF? which at 1978 consumption rates would supply 5-9 yrs.
of natural gas to the reg Ion adjacent to Lake Erie. These estimated resources
represent between .4 and .2 percent of total U.S. proven resources for 1976
and 1% of the reserves for the 13 state region surrounding or near the Great
Lakes. On this scale, Lake Erie's natural gas would not be a significant new
source of energy with the principal incentive being the potential for increased
supplies to local industry in the basin to compensate for potential future cur-
tailments. (Argonne 1978) However, there have been no curtailments of
natural gas to industry in Erie and Niagara Counties, New York in the years
1978, 1979, or 1980 and none are projected for 1981 (data supplied by
National Fuel Gas). Also the employment trend for this region indicates manu-
facturing employment has been decreasing as a percent of total employment
and will continue to decrease in 1981. (Annual Planning Information; Buffalo
Area 1981)
If natural gas was continued to be regulated and if Lake Erie gas was also
regulated, preliminary assessment would indicate that Lake Erie gas would not
be economical to produce for use in interstate commerce. Approximately 1.0
TCF*i5f natural gas would be produced in 198 5 as a result of deregulation of
price proposed by Congress. It is doubtful that any portion of this additional
1.0 TCF of natural gas from deregulation will come from Lake Erie since it
is probable that cheaper gas will be found elsewhere. (Argonne 1978)
ENC-24 / !• The economic analysis presented in the EIS leaves out a number of
factors which are important considerations to the viability of the communities
in the region. These include the following costs:
a) costs to taxpayers for the provision of public services to the
drilling operations,
b) decreased property values
c) decreased income from recreation and tourism
d) decreased attractiveness of the region as a place for permanent
residences
~ Billion Cubic Feet
~~Trillion Cubic Feet
8
-------
e) increased costs of hazardous waste disposal due to the shortage
of available disposal facilities.
f) costs of clean ups
g) loss of future net profits from gas as supply decreases
h) potential loss in revenues from sport and commercial fishing
i) costs of additional water monitoring and treatment
j) costs of repairing environmental damage-
2. Lake Erie gas development would not produce any reduction in gas
cost to the consumer since deregulation has created a national market price.
Any savings due to reduced transportation costs of the gas to market would not
be passed on to the region's gas users.
3. The value of the gas to the region can only increase as more lucrative
supplies decline. Its value to the region in the ground as a reserve and a
hedge against future costs far outweighs any present benefit.
V
' 4. It is likely that the introduction of gas drilling equipment, pipelines,
and waste treatment equipment will act as negative factors to the image of the
shoreline as an area for recreation, and the region as an attractive environ-
ment in which to live. This in turn may compound existing problems of
^declining population, tax base, and employment demand.
' 5. The potential impacts of gas exploration under the gas development
program on the drinking water supply of the region, whether or not the actual
impact is found to be significant, will have a negative affect on the region's
image as an environmentally satisfactory place to reside.
IV. Onland Alternative
1. In the EIS document, the gas development program is compared
against a hypothetical "onland alternative" which was developed for comparison
purposes and not proposed to be viable. In reality, however, an onland alter-
native has been developed, over many years. Independent drilling operations
have been operating. Private individuals have tapped wells for their own use.
Municipalities and public land users have relied on their own gas wells. This
onland activity is a small established industry that already exists and should
develop further. The Lake Erie gas development program would certainly
effect the longevity of the existing industry and could deplete the gas already
being used by individuals and public entities.
r
2. The scope of the "onland alternative" described in the EIS is not
anticipated to be feasible or practical. If ever instituted, it is acknowledged
that it would have serious long term environmental consequences. However,
the existing onland drilling is much smaller in scope. Its impact on the
environment is localized and relatively insignificant. This smaller existing
9
-------
„omments/122
onland gas drilling industry will be viable long into the future with negligible
consequences to the environment, while the proposed EIS "onland alternative"
would have serious long term effects and be only short term in benefits.
Therefore, the comparison of the Lake Erie gas development program against
an "onland alternative" would be more valuable if the onland alternative used
were actually the existing onland drilling operations. Comparing the Lake
Erie gas development program against the existing onland drilling operations
would probably reveal a contrast in benefits to the region. The existing onland
drilling operation would be seen to be a permanent industry at a small scale
with negligible environmental effects. It would provide permanent employment
for a stable number of people without threatening a major source of drinking
water. This is a more orderly, environmentally sound alternative.
Administering the Lake Erie Gas Development Program
1. A program such as the Lake Erie gas development program may be
extremely difficult to administer. Legal, economic, and political realities
would be likely to impede the abilities of public agencies to consistently monitor
and implement the strict procedures being proposed.
2. The procedures proposed in the EIS for the gas development program
would address many environmental and social concerns, however, certain
others should be included:
a) clear power to immediately halt drilling on an emergency and/or
permanent basis for environmental reasons;
b) power to strictly limit the number, size, and specific location of
drilling rigs;
c) ability to regulate placement of land falls and connected land uses
in harmony with local interests;
d) a thorough claim settlement procedure for accidents;
e) compensation to property owners for losses in property value;
f) funds and procedures for reclamation of abandoned onland
facilities;
g) ongoing monitoring of abandoned well sites for leaks and
deterioration; and
h) involvement of local authorities and affected citizens in deter-
mination of buffer zones, land falls and onland facilities.
3. The task force proposed in the EIS should include agencies and indivi-
duals besides the federal and state agencies proposed. The municipalities
affected by the gas development program, shoreline property owners, environ-
mental groups, owners of existing wells and the general citizenry served by
gas in the region are all affected by the proposed gas drilling and thus should
be adequately represented in the task force and on the review committees.
10
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Comments/123
VI. Conclusion
/
1. The proposed gas development program was devised as an extremely
constrained activity in which environmental considerations are paramount and
the best available technologies are utilized. Under this program, the impacts
on land use can, at best, be expected to have negative affects on:
(a) land values
(b) the image of the region as an environmentally attractive place
to reside;
(c) the attractiveness of the region as a location for businesses;
(d) the viability of tourist or recreation related industries;
(e) the viability of land development projects dependent on the
attractiveness of the shoreline; and
(f)' programs to manage the land uses in the coastal zone.
2. The extreme constraint shown in the proposed gas development pro-
gram reflects the best conditions under which Lake Erie natural gas could be
tapped. It is unlikely that under real conditions that the limitations proposed
in the reference program on the number of land falls, and the individual moni-
toring of the entire drilling operation could be uniformly maintained. Instead
it is quite likely that a program with a much larger scope would eventually be
created and the affects on the Lake Erie region already enumerated would be
greatly compounded. The cumulative affects of a gas development program
^with a larger scope than the program described in the EIS would be unacceptable.
3. It seems unlikely that the economic benefits of drilling in Lake Erie
would be passed on to the residents of this region in the form of employment
or decreased energy costs. Instead, it is likely that energy costs would
remain the same as the national market price while certain marginal costs of
production would in fact be born, by tax payers of the region. It is likely that the
region might lose employment in the existing drilling industry, tourism industry
and recreation industry. In addition, residents of the affected areas may face
reductions in property value. In effect," there would be a loss in benefits and
^increase in costs for regional residents.
4. The Lake Erie gas drilling operations,will be short term in nature
while the negative impacts will be Idng term. The gas development program
would produce few benefits to residents and these will be short term in nature
while the negative affects are numerous, potentially threatening the drinking
water supply of several million people.
' 5. The gas development program is acknowledged to be a "best case"
situation, however, it would appear to be extremely difficult to implement. If
such a program were attempted and found to be unsuccessful, a precedent would
have been established which might allow more unacceptable programs to be
established.
11
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uomments/124
ENC-39 6. As carefully as the proposed gas development program is constructed,
any relaxing of standards for evan a brief time period could jeopardize the
integrity of the drinking water source of several million people. Even the most
efficient and dedicated agencies find themselves in situations in which they are
understaffed, or where individuals make errors in judgment on difficult matters.
Any drilling program in Lake Erie would have to be carefully monitored for
35 to 50 years without significant error. This is an awesome assignment that
in the best of situations has proven to have many tenuous elements.
ENC-40 T 7. It does not appear practical to place the most critical resource of the
region in even the faintest tinge of jeopardy for the sake of developing a drilling
program. Any benefits that could be derived from drilling in the lake is
dwarfed by the importance of the lake as a water resource.
8. The ENCRPB staff is in agreement with paragraph 2. 104 of the EIS
which states:
"If Lake Erie natural gas reserves were not developed, some or all of
the excess regional demand might eventually be met by conservation
practices initiated by domestic or industrial end-users because of
rising gas prices, public perception of gas shortages, changes in
priorities of expenditures of personal or corporate funds, or adoption
of alternative forms of energy. In this case, all the adverse environ-
mental impacts of Lake Erie development would be postponed until
such time as the demand for Lake Erie natural gas would necessitate
its development.,. "
12
-------
i,omments/125
References
Argonne National Laboratory. Division of Environmental Impact Studies.
1978. An Examination of Issues Related to U.S. Lake Erie Natural
Gas Development. Argonne, Illinois. 194 pp.
Erie and Niagara Counties Regional Planning Board. Adopted Regional
Plans, Programs, and Goals. 1981. Amherst, New York
Great Lakes Basin Commission. Great Lakes Basin Plan Hazardous
Materials Strategy and Final Environmental Impact Statement.
1980. Detroit, Mich. 83'pp.
Great Lakes Basin Commission. Great Lakes Basin Plan Water Quality
Plan and Final Environmental Impact Statement. 1980. Detroit,
Mich. 74 pp.
International Joint Commission. 1980. Seventh Annual Report: Great
Lakes Water Quality. Ottowa, Canada. 101 pp. (Also Washington,
D.C.)
National Research Council for the Environmental Protection Agency.
Water Quality Criteria. 1972 Washington, D.C. 594 pp.
New York State Department of Labor. Annual Planning Information for
Buffalo Labor Area. 1981. Albany, New York. 87 pp.
New York State. Coastal Management Program. 1979
Albany, New York. 135 pp.
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comments/126
THE CITY OF HURON, OHIO
HURON MUNICIPAL BUILDING
P.O. BOX 327
417 MAIN STREET
HURON, OHIO 44839
January 8, 1981
CITY MANAGER *31-5000
TAX & FINANCE 433-31B5
POLICE DIVISION 433-4114
WATER DEPARTMENT 431-4125
STREET DEPARTMENT 433-3518
BUILDING INSPECTOR 433-4125
FIRE DIVISION OFFICE 433-3544
AREA CODE 419
office of the Mayor
Col. George P. Johnson
Department of the Army .
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Dear Col. Johnson:
Re: Environmental Impact
Statement - U.S. Lake
Erie Natural Gas
MCH-1
MCH-2
MCH-3
In reviewing the Draft Programmatic Environmental Impact Statement
entitled, "U.S. Lake Erie Natural Gas Resource Development" and
being located on that portion of Lake Erie considered for natural
gas drilling, there are certain facts and questions which warrant
a concern for the City of Huron and its citizens.
Because of our location on Lake Erie, the City of Huron has a large
influx of summer tourists, a big boating and marina industry and is
a haven for fishermen. These activities have a great economic impact
on all the businesses of Huron and the governmental services. The
City of Huron also receives its water supply from Lake Erie.
'According to the draft E.I.S. the amount of hydrocarbon gases re-
leased in the waters of Lake Erie during the drilling for natural
gas is unknown. Also the impact these gases may have on the potable
water supply, the .recreational aspect, and commercial and sport fish-
ing in the lake is unknown. The chance of hitting oil and the hand-
ling of this in time to avoid a problem is also unknown. These un-
known factors then naturally have to be a concern for the City of
Huron,
s
According to the draft E.I.S., Lake Erie gas would supply no more
than 0.20% of the United states demand for natural gas in any one
year. Lake Erie gas will not be significant enough to affect any
price of gas to customers. There also is no guarantee that the 10
county area surrounding Lake Erie would get the gas from Lake Erie
in case of a gas shortage. At present there is no basis for saying
Lake Erie gas will be a greater economic benefit if exploited now
or if left in the ground and exploited later in case of a dire
^necessity.
''The draft E.I.S. also states the royalty return to the State of
Ohio will not be large. Also the annual employment of workers may
only be 1500 to 3000 people which is not a great number and this
will be seasonal.
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v.omments/127
Col. Goerge P. Johnson
- 2 -
January 8, 1981
MCH-3
MCH-4
The success ratio of natural gas drilling in Lake Erie is estimated
to be 65%. The assumed life of a well is calculated to be 15 years
and it is estimated after 22 years 2,309 producing wells will be in
operation in the 1,267,000 acres of the Central Basis portion of
Lake Erie which the City of Huron is a part.
In view of the above information and unknowns, the City of Huron is
concerned about any drilling for natural gas in Lake Erie. At the
present time, this is not an objection nor an approval but a state-
ment of concern which at a later time may become an objection to any
nautral gas drilling in Lake Erie.
r
The City of Huron would also request to be put on any information
list and notified of any future development in regard to Lake Erie
natural gas drilling. If public hearings are held, a request is made
that one be held in the City of Huron, Ohio.
V
Sincerely,
George W. Sheard
Mayor
paw
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i.omments/128
/ ¦» ^
City of Buffalo
lS-
James D. Griffin
Matob
Office or the Mayoh
January 9, 1981
District Engineer
U.S. Army Corps of Engineers
Buffalo District
1776 Niagara Street
Buffalo, New York 14207
Gentlemen:
While serving as a New York State Senator, I consis-
tently opposed efforts to establish natural gas drilling
operations in Lake Erie and my additional experience gained
during three years as Mayor of the City of Buffalo, New York,
have reinforced my objections to these proposed efforts.
It is my serious concern that the proposed drilling will
negatively impact upon the substantial achievements attained
during recent years in revitalizing Buffalo's commercial and
industrial climate; in the restoration of the city's residen-
tial neighborhoods; and in the visible improvement in the
quality of Lake Erie water. To unnecessarily endanger this
civic advancement seems to me to be folly.
^ The EIS admits that lake drilling poses the hazards of
explosions and gas leaks, which could result in the emergency
evacuation of substantial areas. The report also states that
pipeline breaks, well blowouts, and marine accidents could
create cancer-causing agents in filtrated drinking water.
These potential hazards are simply intolerable when as many
as one million Western New York residents are threatened by
the possible drilling mishaps.
While the EPA report foresees little restriction on
recreational boating in Lake Erie, it does acknowledge that
drilling platforms and well pipelines could increase naviga-
tional hazards at an area just west of Buffalo, at the entrance
to one of the Great Lakes major harbors.
Positioning gas drilling platforms or pipelines at this
location would jeopardize Buffalo's position as a grain
milling center and steel production facility, as well as doom
our efforts to modernize local rail facilities into a trans-
modal shipping center.
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„dmments/129
District Engineer
Page 2
January 9, 1981
MCB-5 If the local shortage of energy resources was acute,
drilling in Lake Erie might be warranted. But the EIS
ignores the fact that surveys indicate that there is an alter-
nate pool of untapped natural gas under land in the New York
counties adjacent to Lake Erie. Not only would land drilling
for untapped natural gas be environmentally sound, but I have
no doubts that the drilling process would be less expensive
and provide a more reasonably priced source of energy than
would drilling in offshore Lake Erie waters.
In summary, I believe that the EIS provides sufficient
justification for abstaining from any drilling in Lake Erie
at the present time. The additional jeopardy presented to
Buffalo businesses and residents allows me no alternative
but to strongly oppose the proposed lake drilling for natural
gas in proximity to either the City of Buffalo or the shipping
lanes approaching the City.
Sincerely,
JDG/cs
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i.omments/130
ERIE AREA CHAMBER OF COMMERCE
January 9, 1981
ECC-1
ECC-2
District Engineer
U.S. Army Engineer District, Buffalo
1776 Niagra Street
Buffalo, NY. 15207
Attention: Regulatory Functions Branch
After review of the many concerns relative to safety, environmental
constraints, economic, and water quality, the Governmental Affairs Committee
of the Erie Area Chamber of Commerce, at a public forum, reached a favorable
^position on offshore drilling in Lake Erie as it pertains to the Erie Area.
^ This position is conditioned on the premise that before any permits
for offshore drilling are issued there be inplace acceptable enforceable
regulations and standards to insure adequate protection and not to place
in jeopardy the aquatic life in the lake, the source of water supply to
Erie County, and the vast tourist industry, which has a major impact on
^the economic well-being of the Erie Area.
We thank you for the opportunity to participate in this process of
developing the impact statement and plan to submit further comments at the
public hearing at the time of presentation of same.
Sincerely,
£1*+^ C.
Ed Heberlein
Chairman, Governmental Task Force
Frank Witgen
Chairman, Governn^htal Affairs
Committee
cc: Mr. . Paul Horvatin
Mr. Howard Zar
Great Lakes National Program Office
U.S. Environmental Protection Agency
Region 5
536 South Clark Street
Chicago, Illinois 60605
1006 State Street. Erie. P<=>nnsvlvania16501«PhoneS14/454-7191
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comments/131
OFFICERS
WILLIAM I. DAL'RIA
Prendent
768 Richmond Avenue
Buffalo. N.Y 14222
885-3007
IANIS ). HAYES
Tsr Vice Prtadent
PETER REIBEL
2nd Vice President
ARTHUR E. SULLIVAN
3rd Vice Presrdenr
FRANCINE VALVO
Recording Secretary
PIERRE G. BARTHEL
Corresponding Secretary
JOSEPH S. MODlCA
financial Secretary
HAROLD E. BRYAN
Treajurer
ROBERT M. FORSEY
SergeanNat-Arms
Forest District Civic Association
INCORPORATED
19)4-1980
(joittrnment U our iS*tsintst
PIERRE C. BARTHEL, Corresponding Secretary
87 CLAREMONT AVENUE
BUFFALO. NEW YORK 14222
884-0927
12 January 1981
DIRECTORS
Tovie Asarese
It Robert O. Chase
Theodore F. Frank
Emerson Grieve
Fay Kalweit
Carl j. Kolb
Michael Marino
Arvid Svensson
¦^£S"©
Colonel George P. Johnson
District Engineer
U.S. Army Corps of Engineers
1776 Niagara St.
Buffalo, N.Y., 14207
Attention: Regulatory Functions Division
Re: Draft Programmatic Environmental Impact Statement
U.S. Lake Erie Natural Gas Resource Development
Dear Colonel Johnson:
FDCA-1
At a meeting of the Forest District Civic Association, Inc.,
held December 8, 1980 in 927 Grant Street, Buffalo, N.Y.,
the president of the Association, Dr. William J. Dauria, was
authorized to appoint a special committee to review and comment
on the Draft Environment Statement for U.S. Lake Erie
Natural Gas Development.
4
Because the draft impact statement was issued just before the
holidays and the federal government vas in a state of transition,
the committee requested that a delay be granted so that interested
parties could have more time to file comments. The committee
also requested that public hearings be held.
It is our understanding that a delay for filing comments will
not be granted but that public hearings may be held.
We hope that these hearings will provide a format drastically
different from hearings held in the past by members of the New
York State legislature which gave priority to the proponents
of gas drilling.
-------
-omments/132
Forest District Civic Association
INCORPORATED
Corps of Engineers
E.I.S. Draft Impact Statement Comments
Gas Drilling Lake Erie
Page 2 of 5
Contamination of Hater Supply
Our committee has reviewed the E.I.S. and it appears that both
the Corps of Engineers and the U.S. Environmental Agency have
expressed many well-founded concerns, implicit and explicit,
regarding the possible contamination of Lake Erie from drilling
operations.
"Lake Erie is the most precious asset that the City of Buffalo
possesses. We do not feel that the potability of the lake
should be jeopardized for the benefit of corporations solely
^interested in financial gains.
'when the drinking water wupply for over five million persons
is at stake we feel that words such as "may not, should not,
is a potential threat and appears to be minimual," should be
viewed with some skepticism.
Need For Natural Gas
*The need for natural gas, as outlined in paragraphs S.004 and
S.005, is questionable because with the lifting of controls on
the price of gas flowing through interstate pipe lines, the supply
^of gas in the United States has been dramatically increased.
Means To Alleviate Contamination
In paragraph 3.068 mention has been made to the effect that Buffalo
has a "secondary intake" located in an "alternative water supply."
The city has two water Intakes, one located in the Emerald Channel
at the nouth of the Niagara River; the other intake Is in the
Niagara River. Both intakes are supplied by water from Lake Erie.
The intake in the river can be used to supply water to the
Massachusetts Pumping Station. This plant has facilities to
chlorinate water but no facilities for filtration. By no means can
the river intake be called an "alternative supply."
Paragraph 3.065 states that if an acid spill were to occur at
an intake that the PH adjustment might be made with lime or caustic soda.
-------
^omments/133
Forest District Civic Association
INCORPORATED
FDCA-6
FDCA-7
Corps of Engineers
E.I.S, Draft Impact Statement Comments
Gas Drilling Lake Erie
Page 3 of 5
Means Ta Alleviate Contamination (Cont.)
*
Paragraph 3.062 states that hydrogen sulfide may be oxidized
rapidly to sulfate with the use of chloride or potassium
permanganate. The city has facilities to add additional chlorine
to the water but this could pose a threat to the health of
water consumers as pointed out in paragraph S.030.
''The addition of these chemicals to the water supply to avoid
contamination will pose an additional financial burden on water
consumers. These materials must be purchased and stockpiled
in advance of an emergency. Furthermore, it will be necessary
to purchase and maintain additional equipment to introduce the
chemicals.
It would appear, that unless some measures are taken to have the
drilling operators pay for these supplies and equipment, that
water consumers will be subsidizing drilling operations.
FDCA-8
Disposal Of Residuals From Drilling Operations
Paragraphs S.013, S.014 and S.015, make reference to the disposal
of residuals that must be collected and brought to land disposals.
<»
Western New York is now experiencing an acute shortage of approved
landfill space for solid waste disposal. Before any permits for
drilling are granted the landfill space for disposal of residuals
must be identified and acquired.
Accidents
Paragraphs S.018, S.019 and S.020 make references to the
contamination that might be experienced as the result of an
accident.
FDCA-9
Here again we find the usuage of ambiguous words as highly unlikely,
would be minimal, would not substanially impact water supply.
These references would seem to be conclusive evidence that the
persons involved in writing the report are not sure of what would
actually happen. Such assurances are unsatisfactory.
Paragraphs 1.140 through 1.146 and Table 1-35 point out
a number of consequences that might endanger the environment of
the Lake as the result of accidents.
When one considers that the taxpayers have spent millions of
dollars to clean up the Lake and still have a long way to go,
that even the mention of contamination, albeit small, should
not be tolerated.
-------
uomments/134
Forest District Civic Association
INCORPORATED
FDCA-10
Corps of Engineers
E.I.S. Draft Impact Statement Comments
Gas Drilling Lake Erie
Page 4 of 5
Electric Generating Plants and Food Processing Plants
At ttio of the public meetings conducted by New State Legislatures
In the past concerning lake drilling, we have posed a question about
the adverse effect that contaminated Hater you have upon the steam
electric generating plants at Dunkirk and Tonawanda.
We have never had an answer to these questions,
any reference to these plants in the E.I.S.
We cannot find
FDCA-11
We have also posed the same question with regard to the many food
processing plants located in the area that depend upon a supply of potable
water. This question has never been resolved and the E.I.S,
does not make any reference to the question.
The endangerment of the electric power generating stations and
food processing plants would seem to outbalance any benefical
effects that might economically accure to the State of New York
through revenues obtained from gas drilling.
FDCA-12
FDCA-13
FDCA-14
Monitoring of Drilling Operations
Because the lands under the lake are owned by the State of New York,
the Commonwealth of Pennsylvania and the State of Ohio a proposed
set of guidelines is recommended in Appendix D, paragraphs
D.014 through D.041.
We cannot fault this program which will require enabling legislation
in all three states because there appears to be considerable
discrepancy in the standards established by the State of New York
and the Commonwealth of Pennsylvania as outlined in Table Al of the
Appendix.
Both the Commonwealth and the State of New York require liability
insurance of $1 million for each adverse occurence.
We feel that this amount is much too small to pay for damage that
would occur because of a spill.
'The track record of the New York State Department of Conservation,
in our opinion, has not been too good. At present the department
is unable to properly supervise the operation of authorized land
fills because of a shortage of personnel and funds.
There does not appear to be any recommendations regarding the
payment of costs for monitoring services. This burden should not
be paid by the taxpayers. It has not been established that the
cost of safe monitoring would enable the project to be economically
feasable.
-------
Comments/135
Forest Distract Civic Association
INCORPORATED
Corps of Engineers
E.I.S. Draft Impact Statement Comments
Gas Drilling Lake Erie
Page 5 of 5
Conclusion
This whole debate may be summed up into a simple statement:
Do we want a new supply of natural gas that is not needed
rr.do we want a supply of pure water that is vital to life.
-f anything can go wrong it will. The E.I.S. points out
a number of things that may go wrong.
Let's not make Lake Erie into another Love Canal.
Sincerely,
Forest District Civic Association, Inc.
For the Committee
Pierre G. Barthel
Corresponding Secretary
CC: Dr. ton. J. Dauria
Mary M. Barthel
Robert 0. Chase
Felix L. Katzmarek
Michael J. Martin
Robert B. Robinson
-------
Comments/136
ELMA ENVIRONMENTAL COMMISSION
ELMA, NEW YORK 14059
January 20, 1921
Project Jianager Arthur Marks
U. S. Army Corps of Iligineers
1776 Iliagara Street
Buffalo, K. Y. 1U207
Subjects Gas Drilling in Lake Erie
Bear Sir:
Please forgive our tardiness in responding to the EAP on the subject natter.
We've been a little under the weather with whatever it is that's currently going
the rounds.
'At the regular meeting, January 1l+th, the Elma Environmental Commission (nine members,
1 associate member), authorized the Secretary to address a letter to you indicating
their support for the positions expressed by County Executive Rutkowski md l-layor
Griffin in attached news articles.
'"in addition, members expressed the following:
''"l) They question the validity of using Canada's experience as an indication that
it would be duplicated by drillers on the American side of the lake. It was felt
there were differences in the weather patterns that would cause more stress on rig
structures on the J-jnerican side than on the Canadian side. In addition, there does
appear to be a more respectful attitude by Canadian interests toward their environ-
ment and their laws than is currently exhibited by Americrji interests.
'2) As mentioned by County Executive JJutkowski, we question the wisdom of endangering
our water supply in quest of a gas supply. We have noted in the "YS Hivironmental
Bulletin, literaly hundreds of gas wells coming on line in Erie and neighboring
Counties, CUT LAi-ID. Looking a little farther across the State, we see the areas
around Hew York City in real distress because of a drought. Given the choice, we
can live without gas, we cannot live without water,
s
Respectfully submitted,
"aay=-
ELKA EKVIROITENTAL cokhssioh
Bruce Bauer, Chairman
Fred Juliano, Vice-Chairman
Marilyn Frank, Secretary-Treasurer
Members: Joseph Brunner
Patricia Koch
Muriel liartin
Cindy Oliver
John Rupp
John Varchocki
Assoc. "fember: Sue Camillo
-------
Comments/137
MEMBERS NEW YORK STATE
CONSERVATION COUNCIL
ALLEGANY COUNTY FEDERATION
CATTARAUQAS COUNTY FEDERATION
CHAUTAUQUA COUNTY FEDERATION
ERIE COUNTY FEDERATION
NIAGARA COUNTY FEDERATION
WYOMING COUNTY FEDERATION
Tfle&t&ut "Hew-
Sav&tMMMtal yedetatiM,
1190 Parkhurst Blvd.
Tonawanda, Nerr Tork
January 21, 1981
14150
Co La Mi L <*Eo&t£ P. J~t>
0. S. Corps of Engineers
% Mr. Arthur Marks, Permit Section
1774 Niagara Street, Buffalo, Kerr Tork 14207
WEF-1
WEF-2
Dear Sir,
' On Sunday, January 18, 1981 by unanimous rote, our Federation
of 6 counties emphatically has gone on record against cue proposed
Lake Erie plan for gas drilling* Our main concern is for the water
quality of Lake Erie and the possibility of Its degradation for the
Billions of those dependent upon It.
A main concern Is that of methane loading It "Canadian
drilling waters show an above background area of ethane, propane and
laobutane, <4-12 tinea greater than D. 2. waters. Canadian waters also
hofl significantly higher mean concentrations of these constituents11.
This and other factors are stated in Zapotsky's and TJhite«s report
entitled, "A Reconnaissance Survey for Lightweight and Caroon Tetrochloriae
extractaole Hydrocarbons In the Central and Eastern Basins of Lake Brie1*
published October 1980*
Ihen the Ner Tork State Conservation Council convenes in
late February or early March of this year 1 will reeomnend similar
action by the nhole Council comprising all counties in our state9 of
which there are 62.
Respectfully suonittee,
Jr^ H-
H. Buns, President
This message comes to you on re-cycled paper
-------
Comments/138
January H, 1931
Col. George P. Johnson
District Engineer
U.S. Array Engineer District
1776 Niagara Street
Buffalo, NY 14207
Dear Colonel Johnson,
The Erie County Council of Sportsmen's Clubs is vitally interested
in the proposed drilling for natural gas in Lake Erie. 7/hile we would
afree that the economic benefits of such a move are important, we also
fo^l that the potential for accidents in such development as currently
described in the Corps D.E.I.S. poses serious problems that would be
not only enviornmentally hazardous but also economically destructive
to the Lake Erie coast line of Pennsylvania.
ECS-1r* 0ur judgment in this matter is supported by evidence from two
major professional sources. One is testimony given in Karrisburg in
1963 by the Erie City Water Department, which was so compelling that
it produced an injunction against drilling in the lake at that tine.
We feel the evidence generated in those hearings is still valid for
consideration in the present situation and encourage your people to
review this testimony before deciding to issue any permits for lake
drilling.
zcs-2f Our second source is the recent review of the problem made by the
JErie County Health Department, which encompasses many of our concerns
Ion the lake's fishery, and water quality as well as impacts on Presque
[isle State Park.
Therefore, we echo this department's request that no permits be
issued for drilling for natural gas in Lake Erie until all enviornmental
problems are resolved connected with such operations.
Yours truly,
v_Richard J. Kufrfak
Chairman, Enviornmental Committee
Erie Co. Council of Sportsmen Clubs
-------
Comments/139
Supervisor
LEO J. FALLON
Couiofmsn
GEORGE E. DANVLUK
FRANCIS J MET2
SALIVA. STEPHENSON
BARBARA C WICKS
Town Clerk
PATRICIA A. MEAD
CJortn ojHamburg
Town Attorney
VINCENT J. SORRENTINQ
Supt o( Highways
RICHARD A, SMITH
Reoeiverof Ta«es
ROBERT A. MARS
S-6100 SOUTH PARK AVENUE HAMBURG, NEW YORK 14075
TEL: (716) 649-6111
February 10, 1981
TOH-1
Col. George P. Johnson
Corp. of Engineers
Buffalo District
1776 Niagara Street
Buffalo, New York 14207
Dear Col. Johnson:
We are enclosing copies of the resolutions
that were adopted at the regular meeting of the Town
Board on the 9th of February, 1981.
These are to be included in '.the public
hearing on Wednesday, February 11, 1981.
Thank you.
PAM:ad
Enc.
Sincerely,
/&- ¦
Patricia A. Mead
Town Clerk
-------
Comments/140
TOVN OF HAMBURG RESOLUXIOtI
STATE OF NEW YORK )
COUNTY OF ERIE * ) SS.
TOWN OF HAMBURG )
I, Patricia A. Mea3 .'Town Clerk
of the Town of Hamburg, Erie County, New York, do hereby certify
that at a regular meeting of the Town Boaxd of the afore-
said town, on the ijth day of February ,
at the Hamburg Town Hall, S6100 South Park Avenue, Hamburg, New
York, the following resolution was adopted, every member present
voting therefor, to wit: —
The following resolution was offered by
Councilman Wicks, who moved its adoption,
seconded by Councilman Stephenson,
WHEREAS, the U. S. Army Corp. of Engineers
is holding a Bearing on February 11, 19S1 at 7:30 P. H.
I
in Buffalo, New York on GAS DRILLING IN LAKE ERIE at the
Buffalo State Communication Center and
WHEREAS, the Town of Hamburg Town Board has taken
a position of opposition to Gas Drilling in Lake Erie,
by Resolution on May 12, 1969, February 11, 1974 and March
14, 1977 and has been represented at several environmental
hearings to voice opposition to drilling in Lake Erie
.and
•WHEREAS, the basic responsibility of the Town
Board of Hamburg remains the protection of the Towns drink-
ing water-supply, and its fishing and recreational use of
Lake Erie,
THEREFORE,'BE IT.RESOLVEDihat the Town Board of
Hasburg reiterate:its position of opposition to Drilling
in Lake Erie particularly in light of the Information
which denotes the lake area off the shore of Hamburg to
be suitable for Drilling
•K .
and be it further
RESOLVED that the May 12 1969 Resolution . which
••JLd:
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Comments/141
Pennsylvania Electric Company
10OI Bfooa Siieet
Johnstcwn Pennsylvania 15907
814 533-8111
Writei's Direci Dial Numbei
811+ 533-6568
November 18, 1980
Colonel George P. Johnson
District Engineer
Regulatory Functions Branch
Buffalo District Corps of Engineers
1776 Niagra Street
Buffalo, MY 1U207
Dear Colonel Johnson:
SUBJECT: Comments on Draft Programmatic EIS
U.S. Lake Erie Natural Gas Resource Development
The following comments are submitted on behalf of Pennsylvania Electric
Company (Penelec), a subsidiary of General Public Utilities Corporation (GPU).
During our review of the subject draft EIS, we noted that two GPU projects
were referenced in Table 3-16 for Erie County, Pennsylvania. For clarification,
the following information is offered:
In December, 1979, GPU Service Corporation submitted an environmental
report to the U.S. EPA Region III, Philadelphia, which was prepared in
support of a coal fired steam electric generating station to be con-
structed in Girard Township, Erie County, Pennsylvania. A copy was also
sent to Mr. Arthur Marks of your office. The applicant, Penelec, has
worked closely with the U.S. EPA in their preparation of an EIS for this
project. The scheduled date of commercial operation for Coho, as stated
in our ER, is June, 1988.
On June 2$, 1980, Jersey Central Power & Light Company (JCP&L), also a
subsidiary of GPU, filed an application with the Department of Energy's
Economic Regulatory Administration for a Presidential Permit to install
and maintain electric power transmission cables under Lake Erie from
Ontario Hydro System in Canada to the Coho site, and then overland by
overhead transmission lines to GPU's Erie West Substation. From there
power would be delivered across an existing transmission system to the
JCP&L service territory in New Jersey. On October 30, 1980, JCP&L sub-
mitted an environmental report to the ERA in support of the Presidential
Permit application. On November 5« & copy of this report was also sent
to Mr. Len Kotkiewicz of your office. The project consists of construc-
tion of a 1000 MW, ±250 to 1325 Kv dc cable system from the U.S./Canadian
international border to the Coho site, overhead transmission lines and
appropriate dc/ac invertor station. The scheduled operation date is
December, 1981*.
GPU-1 1• Coho Generating Station - Unit 1
GPU-2
Lake Erie Interconnection Project
Pennsylvania Electric Company is a Member ol the General Public Utilities System
-------
comments/142
GPU-3
Colonel George P. Johnson -2- November 18, 1980
The effects of potential natural gas drilling in Lake Erie have been con-
sidered during the development of both of these GPU projects. GPU will continue
to coordinate with all responsible agencies to assure that any future natural
gas development activities and the planned future generating station and sub-
marine cable system will be able to co-exist without interference or adverse
environmental effects.
Thank you for the opportunity of allowing us to comment on your DEIS for
natural gas resource development in Lake Erie.
Very truly yours,
Jf&S
James R. King
Environmental Scientist
den
cc: Messrs:
P. S. Feldman
J. W. Henry
G. E. Huston
A. Narks
-------
Comments/143
Pennsylvania Electric Company
1001 8rood Street
Johnstown Pennsylvania 15907
814 633-8111
Writer's Direct Dial NumOer
811+ 533-8576
January 28, 1981
Mr. Arthur K. Marks
U. S. Army Corps of Engineers
1776 Niagara Street
Buffalo, NY 11+207
Dear Mr. Marks:
GPU-4
SUBJECT: Lake Erie Natural Gas Drilling DEIS
On behalf of the Pennsylvania Electric Company, which is an operating
subsidiary of General Public Utilities Corporation, and. our two sister
utilities, Jersey Central Power & Light Company and Metropolitan Edison
Company, I wish to make the following comments concerning the Corps of
Engineers and EPA's DEIS for offshore gas drilling.
Penelec strongly urges that the Corps and EPA establish a buffer zone
on either side of existing or currently proposed utility installations.
Such a buffer zone is mandatory not only to protect the utility's invest-
ment, but to ensure that drilling will in no way interrupt the service(s)
provided by the utility. It is our recommendation that a buffer of 300
meters on either side of existing or proposed facilities be required to
ensure the safety and reliability of utility installations.
On behalf of the GPU system, I wish to thank you for allowing us to
submit our comments for review by the Corps. Should you have any addi-
tional questions concerning the issue of a "buffer zone" please feel free
to contact me at the above telephone number.
Very truly yours,
Paul S. Feldman
Supervisor-Licensing-G^neration
den
Pennsylvania Electric Company is a Member of the General Public Utilities System
-------
v.omments/144
Defroif
Edison
2000 Second Avenue
Detroit. Michigan 48226
(313) 237-8000
December 11, 1980
George P. Johnson
Colonel, Corps of Engineers
District Engineer
Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Dear Colonel Johnson:
Thank you for the opportunity to review the enclosed EXS
on Lake Erie natural gas development. The unmarked report
is being returned for reuse.
DTED-1 In reviewing the report I noticed there is no discussion
of the very long Canadian experience with natural gas develop-
ment in Lake Erie. The enclosed abstract from the report
noted summarizes this successful experience. Note that the
author of this writeup was Glen Crewe of the Ontario Ministry
of Natural Resources.
DTED-2 Finally, X find it strange that in light of our extreme
dependence on foreign oil, we are not exploring ways to extract
the known oil resource under Lake Erie in an environmentally
acceptable way.
JPL :mj f
Attachments
Lagowski
Market/Development
-------
comments/145
January 5, 1981
Colonel George P. Johnson, District Engineer
U.S. Army Corps of Engineers, Buffalo District
1776 Niagara Street
Buffalo, NY 14207
ATTENTION: Regulatory Functions Branch
Dear Colonel Johnson:
As per your letter dated November 10, 1980, the Draft Programmatic Environ-
mental Impact Statement: U.S. Lake Erie Natural Gas Resource Development has
been reviewed, and our comments are presented below. Due to time restraints,
it is not possible to comment on all the salient points of this document at
this time. Therefore, this letter will present the major criticisms we have
to date. Our comments on the potential environmental Impacts of drilling for
natural gas on Lake Erie will be reserved until the time a permit application
is submitted to your office.
As regards to our comments on this D.E.I.S., I would first like to point
out informal, undocumented conversations with unidentified persons are not
generally considered acceptable sources of information. For example, on page
1-20, some of the data dealing with the reservoirs of natural gas were obtained
through "informal discussions with geologists and operators". In the first para-
graph on page 1-23, a sentence begins "Most field operators admit...". These
examples are just two of a number of cases where questionable references are
cited. The reviewer Is unable to judge the accuracy or reliability of the infor-
mation presented without some knowledge of the credibility and qualifications of
the sources. Since some of the information from the unidentified sources are
used to form a number of the assumptions on which the "Reference Program" is
based, the accuracy and acceptability of the entire program is subject to question.
If the presently unidentified sources of "informal" information cannot be identi-
fied and documented, all information derived from these sources should be deleted
from the D.E.I.S. as being unacceptable. The accuracy of the information in this
D.E.I.S. is important due to the fact that this report may serve as the foundation
for environmental assessments of future Lake Erie drilling programs.
RC-2 /¦ second comment regards the treatment given the economic feasibility of
f the "reference program" in the D.E.I.S. The three states will not realize the
I projected revenues if the wells are not drilled. Appendix B presents the costs
R€CRA P£S€ARCH, INC P.O. Dox 448 / Tonowondo. New York 141 SO / (716)636-4200
-------
L"omments/146
Colonel George P. Johnson
Page 2
January 5, 1981
RC-2
of equipment, etc., a developer will incur if he implements the "reference pro-
gram". What the D.E.I.S. does not consider, and cannot possibly address, are the
sometimes significant costs borne by applicants during the permit process. For
example, the preparation of a D.E.I.S. can be costly, as your office knows after
spending around $2 million on this document. Also, given the public controversy
surrounding the Lake Erie drilling program, state and federal permit hearings
are a possibility. If these hearings are prolonged, the applicant will be forced
to expend significant funds covering the hearing costs, as illustrated by the
N.Y.S.D.E.C. hearings on the S.C.A. and CECOS landfill expansion permits. If
the costs associated with the project are too large for the potential developers,
no drillers will undertake the work. Without considering the cost to the appli-
cant, the economic feasibility of the program cannot be accurately assessed.
RC-3
s
Our third comment deals with the presentation of information in the alter-
natives to the proposed program section. As discussed on page vii of the summary,
the estimated reserves of natural gas obtainable from Lake Erie is approximately
1.5 TCF. The basic question in the alternatives section should be: Can an equal
or larger amount of natural gas be recovered from an alternative source without
posing the potential adverse impacts associated with drilling on Lake Erie? On
page 2-10, geopressured aquifers are estimated to contain 3,000 to 49,000 TCF.
If only 2% is recovered (the lower estimate cited), there is still a potential
for recovering 60 TCF; a much larger volume than can be obtained from Lake Erie
drilling. On a more regional scale, on page 2-17, the proven reserves for land-
based natural gas is 1.1 TCF with the estimated reserves recoverable by available
technology being 285 TCF.
Combinations of alternatives must also be considered. Although one source
may have certain limitations, two or three sources used in combination could
supply the needed natural gas without the need for Lake Erie drilling. A simple
review of the information presented in the alternatives section of this D.E.I.S.,
coupled with the admission of a current glut in the natural gas supplies in the
region, suggests alternate sources of natural gas are available in larger quan-
tities than can be realized from Lake Erie. Also, given the present stage of
the Lake Erie drilling program, the mid-1980's date given for medium-BTU Coal
Gasification plants (p. 2-14) in the United States coincides with the time frame
•of possible Lake Erie drilling start-up. Therefore, this alternate source cannot
be so readily dismissed.
Thank you for allowing us this opportunity to comment on the Lake Erie
D.E.I.S. We would appreciate the opportunity to review and comment on similar
Corps of Engineers' projects in the future.
KCO:jks
R6CRA R£S€ARCH, INC
Sincerely yours,
RECRA RESEARCH, INC.
Kevin C. Owen
Environmental Specialist
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Comments/147
STATE 0NSVERS1TY COLLEGE AT BUFFALO
1300 ELM WOOD AVENUE • BUFFALO. N. Y. 14222 • Telephone 716 878-5422
7 January 1980
Great lakes
laboratory
Robert A. Sweeney, Director
GLL-1
GLL-2
GLL-3
[
[
Col. George P. Johnson, District Engineer
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York \k207
REF: Draft EIS-"U.S. Lake Erie Natural Gas Resource Development"
Dear Col. Johnson:
I am submitting the following preliminary comments regarding the
above in order to meet the 12 January 1981 deadline as stated in your
letter of 10 November 1980. However, per our telephone conversation
of last week, I understand that you will accept comments of a substantive
nature up to the time of the public hearing which is tentatively
scheduled for the end of this month.
We are not in agreement with many of the conclusions in the draft
and the manner in which several topics were handled. The matter of gas
supply on a national basis was not adequately addressed in the EIS. As
a consequence we question whether there is a need for exploration for
gas in Lake Erie in view of the availability of gas from other sources.
Information on the latter, which was the subject of a recent "60 Minutes"
program on CBS-TV, can be obtained from the U.S. Department of Energy.
This information was known when the EIS was prepared. The gas problem
primarily is a matter of distribution rather than availability. As
deregulation of the price of inter-state gas has occurred, the supply
has dramatically increased. We believe that there are more than
sufficient sources which can be used until the gasification of coal and
other technologies can generate alternate supplies of methane that could
economically compete with gas withdrawn from subsurface deposits.
The Federal curtailments on gas supplies in the Lake Erie Basin
gas discussed on pages l-'t and 1-5 are no longer applicable. Given the
nature of the national distribution and pricing system, statements that
industrial development in an area will be limited because of a lack of
gas in that area are incorrect. The inference that Lake Erie gas would
be restricted for use in the Basin is misleading at best. The EIS fails
to state that the Lake Erie gas would go into a national pool. The
failure to point out the above is a major and serious omission.
CONSERVE RESOURCES —RECYCLE
-------
Comments/148
Col. George P. Johnson
-page 2-
Our other major concerns are in the area of risk. The EIS fails
to discuss thoroughly the consequences of an explosion or fire on a rig.
Yet the latter has been a major source of contamination in off-shore
drilling operations in the Gulf of Mexico and elsewhere. Likewise
there have been similar incidents with land based drilling rigs in New
York, Pennsylvania and Ohio taping the same geologic formations as those
reported to extend under Lake Erie. There has been at least eight such
incidents in the past ten years in the area adjacent to Lake Erie.
Furthermore, one of the Canadian jack-ups operating in Lake Erie had a
major accident and fire in 1980 which necessitated abandoning the rig by
most personnel. Fortunately the accident occurred before they had hit a
gas formation and few pollutants were released. In view of these realities,
a major scenerio should be written on the possible impacts of such an
s Incident in Lake Erie including effects on public water supplies.
The authors appear to have a poor grasp of knowledge regarding the
nature of currents and dispersement of liquids of different density in the
Great Lakes. This is evident in the discussion on pages 4-26 and 4-27.
Pollutants in a water mass with an initially different density may take a
considerable period of time and, in the case of flowing water, distance
to become diluted. In Lake Erie, where surface currents can reach
80 cm/sec and subsurface currents 20 cm/sec, contaminants diluted by as
little as fifty percent could reach an intake between 15 and .60 minutes,
v, if dri11ing is permi tted within 0.5 km of the latter. Not only should
the impact of chlorine as polyethylene glycol be explored before drilling
is permitted, but the effects of chlorination on the other hydrocarbons
associated with natural gas and the liquids used in drilling operations
also should be thoroughly investigated. Again no attempt was made by
those writing the EIS to research the literature regarding such potential
problems.
The EIS fails to address the availability of alternate water supplies
in event of severe contamination. When they say that the City of Buffalo
has a second intake they neglect to note that the emergency intake withdraws
water from the same watermass ("Emeral Channel") as the primary intake.
They also fail to mention that there are no screens or filtering systems
at the emergency intake. The bottom line is that there is no adequate
source of water for most of those who use Lake Erie as a supply for
domestic and industrial use.
We question the research regarding seismic conditions. The data
included in the report appear to have been taken from the 1977 Lawler,
Matusky and Shelly Report, which was the subject of considerable criticism.
However, we will defer to the League of Women Voters to comment on that
point.
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Comments/149
Col. George P. Johnson
-page 3"
We believe that there is sufficient justification to necessitate
that numerous sections of the draft be rewritten to provide a more
balanced and objective treatment of much of the subject matter. More
economic information on the cost of spill ciean-up and the development
of an adequate monitoring and alternate water supplies should be
included.
Sincerely,
RAS:s
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i.omments/150
MINOR FISHERIES
Rdl Box 109
E. Springfield, Pa. 16411
(814) 922-3948
P2JK3YLVAXIA FISH FH0DUC52S ASSOCLlTIOK
Rd .-ft 3ox 1.09 3. Springfield ra 16411
.Tanuary Q,19'30
U.S. Army Corps, of !2ngir.eers
I776 Niagara St
Buffalo, WY 14207
Gentlemen: He: draft programmatic environmental Impact statement: US LAE3 ERIE
NATURAL GAS RESOURCE D2VELOPH3NT j page 3-16 subsection 3.057-"In Pennsylvania
It Is doubtful that commercial fishing still takes place".
Fbr your information approxinateiy 1 b?. paychecks are dependant on the commercial
fishing industry in the Commenwaalth of Pennsylvania. Twelve tugs, which with their
gear represent approximately a 2 million dollar Jtrivate capital investment, fish
the waters of Pennsylvania. With the advent of pollution control a revltallaation
of our industry has taken place and we look to a promising future with the commercial
harvest of presently underutilised species contributing to an overall Increased
food production. Our concern is that the present water quality of the eastern basin
be maintained.
Ve have seen where the commercial fleet In Canada have had problems with the
operation of drilling equipment in the lake. The movement of rigs and pipe sometimes
causes damage to nets, expensive trawls can become entangled on the well heads
despite deflectors, tfe would expect to be able to resolve such problems. Ve also
expect to be Included in any further decisions that would affect the future of
lake Hire. Sincerely,
s
CarylAnn Minor, secretary
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tomments/151
"Nature it pleated with timplicity." — Isaac Newton
435 CRESCENT AVENUE
BUFFALO 14, N. Y.
nivccia.!
Jsn< 8, 1981
United States Army Corps of Engineers:
RESPONSE TO YOUR REUUCST FOR ENVIRONMENTAL IMPACT STATEMENTS ON LAKE DRILLING
We are opposed to drilling in the Great Lakes for gas and oil because
the need is so small in proportion to the environmental risk. The I960
American Ga3 Association report "The Gas Energy Supply Outlook
1980-2000"forecasts a good supply of natural gas from proven land reserves
without any gas from the Great Lakes, so there is no need for lake drilling
during this period.
The plana presented are ambiguous or neglectful in stating all of the
environmental hazards. The Great Lakes are the world's greatest supply of
good drinking water. Just as industrial pollution in the West is BHrinngexxn;
causing "acid-rain and snow" in New York State, drilling in the upper
Great Lakes can cause pollution in bake Erie and contaminate Buffalo's
water supply.
We suggests
Standards set in the 197B Water Quality Agreement must be
mandatory.
Higher earthquake risk must be considered , especially since
thers aro many nuclear reactors and the Ue3t Valley repository
of nuclear wastes in the area. Also many dangerous chemicals
are being manufactured along the shores of the Great Lakes.
Canadian experience cannot be used as a basis for study since
most of their drilling has been in shallow, off-shore water -
not deep-water drilling in the lake.
Both the health and economic costs of water supply must be
considered. Sufficient funds must be bonded to cover
possible oil-spills, accidents, damages to water supplies,
damages tn persons harmed by change in the water supply.
Local people must be trained for clean-up operation, studies
must explore the possibility of contamingtion thru drinking
water, the atmosphere or the food chain by PCB's from heat
exchangers and mercury from anodes. Dlow-out-praventors are
far from fool-proof. Moro adequate fire-control systems are
needed as witness the recent Mr. Neil fire in Lake Erie.
What are the plans for re-servicing production equipment?
In laying pipe will the sediments be distuiubed,re-introducing
contaminants into the water column? Will phosphorous from
the sediments enter the water column and cause greater growth
of algae with tha resultant change in taste, end oxygen
depletion in the water ?
Therefore we recommend that no lake drilling be considered until 75
of tha land's proven resources bs depleted, and that before any future
lake drilling is undertaken, there be considerable improvement in the state
of the art.
-------
\^dd. ^dL*~eT^ —
"75^ trrrwruj X7/J/)n ^ ^
Jit jf/ jjf~U **A o** • '
-------
wjmments/153
Columbia Gas 3yste/y\ Service Corporation
ROBERT w WELCH JR
Vice PRESIDENT
gNVlRONMgNTAl. AFPAlRS
"OSS'
20 MONTCHANlV qoaq
WlUMINCTQN OeuAWARE 19807
January 9, 1981
Colonel George P. Johnson
District Engineer
Department of the Army
Buffalo District, COE
1776 Niagra Street
Buffalo, New York 14207
Dear Colonel Johnson:
Re: Draft Programmatic EIS, "U.S. Lake Erie
Natural Gas Resource Development"
Columbia Gas System appreciates the opportunity
to comment on the Draft Programmatic Environmental Impact
Statement: U.S. Lake Erie Natural Gas Resource Development.
Columbia is one of the largest natural gas systems
in the United States and is composed of The Columbia Gas
System, Inc., a registered public utility holding company, a
service company and seventeen operating subsidiaries. The
operating subsidiaries are primarily engaged in the production,
purchase, storage, transmission and distribution of natural
gas at wholesale and retail. Columbia supplies directly through
its retail operations, or indirectly through other utilities,
the gas requirements of about 4,200,000 customers in an area
having a population of approximately 18,000,000. Columbia's
service area includes large parts of the states of Ohio,
Pennsylvania, Kentucky, New York, Virginia, West Virginia,
Maryland and the District of Columbia. Columbia serves at
retail 1,850,000 customers residing in communities with a total
population of 7,400,000.
Columbia has an interest in this proceeding and fur-
nishes the following section-by-section and general comments for
consideration.
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wOmments/154
-2-
Page 1-3, Demand for Natural Gas by Regional Industrial
Gas Consumers *
css-1 There should be an additional section which dis-
cusses the use of gas by residential customers in this region
with some detail of the 1976-77 natural gas shortage problems
experienced by both industry and residential sectors.
Page 1-4. S. 1.014
CSS-2 f This section should have quantified the economic
impact of "plant closing and employee layoffs" in numerical
terms of dollars and unemployment rates of the various states
involved. Examples from the 76-77 winter gas shortage would be
illustrative.
Page 1-7. S. 1.021. Lines 12-14
css-3 f This sentence implies that the Reference Program
will establish environmental acceptability and form the basis
for rejection or acceptance of natural gas development in Lake
Erie. Development of Lake Erie gas will have to be based on
several considerations—economic, political, energy supply and
demand needs and the beneficial environmental results from the
use of natural gas as a fuel in place of oil and coal. Acceptance
or rejection of a program must be based on all of these considera-
tions, not solely on environmental acceptability of certain per-
mitting activities associated with energy development.
Page 1-37. S. 1.063
css-4 f ^ask Force mentioned in this paragraph should
have representatives from the Natural Gas Industry to provide
their expertise in the engineering, environmental and legal as-
pects of the development of this resource.
Page 1-40. Table 1-10
CSS-5f/ *"s aPParent that appreciable time has passed
since this EIS was prepared because some of the information
regarding applicable regulations is wrong. Drilling muds,
for example, are exempt from the provisions of the Resource
Conservation and Recovery Act (RCRA).
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uomments/155
-3-
CSS-6
CSS-7
CSS-8
The Canadians have decades of experience in
drilling for natural gas on their side of Lake Erie. It
would be useful if the DEIS described how the Canadians
handled various environmental aspects of drilling in Lake
Erie, as for example, the handling of drill cuttings.
Page 1-47. S. 1.074
The Draft EIS does not consider FERC's role in
the regulatory scheme. This must be included. If a final
EIS is adopted, the other agencies involved should publish a
memorandum of understanding to define the limits of any further
site-specific EIS that may be needed before an activity can -
begin.
Page 1-83, S. 1.111
* This paragraph and certain following paragraphs
(discussed below) will have to be revised to reflect the
Hazardous Waste Management System regulations promulgated
May 19, 1980 (45 FR 33066).
CSS-9
Page 1-83. S. 1.113
" Section 261.4(b) of the RCRA excludes certain solid
wastes as hazardous wastes. These include "drilling fluids,
produced waters, and other wastes associated with the exploration,
development or production of crude oil, natural gas or geothermal
energy." Thus, the last sentence of this paragraph is incorrect.
These materials are neither special nor hazardous wastes. In
fact, RCRA does not have a category of "special wastes" and this
.designation should be deleted from the DPEIS.
Page 1-83. S. 1.114
css-10 { The extraction procedure has been promulgated at
[Appendix II, 45 FR 33127 (May 19, 1980); this paragraph must
[be revised.
Page 1-83. S. 1.115 through 1.121
css-11 { These paragraphs need to be revised or deleted to
I reflect the exclusion of Section 261.4(b)(5) and the final
(hazardous waste regulations.
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-omments/156
-4-
Page 2-23. S. 2.088
css-12f It should not be assumed that aerial crossings of
rivers (suspended pipelines) are common industry practices.
In fact, most all pipeline crossings of streams involve ex-
cavation of a trench and subsequent pipeline burial below the
stream bottom. Aerial crossings are used when the physical
parameters of the river indicate that a buried crossing is
not desirable. Also, the DFEIS should reference DOT regula-
tions (Part 191 and Part 192, Title 49 CFR).
Page 3-9. S. 3.027
(i.e.,
CSS—131 Consistency in units of measure would be helpful,
use all metric, or all English units or both in all cases.
Page 3-9. S. 3.029
CSS-14
Will the study of Zapotosky and White, 1980 be made
available to the public? This section does not indicate any
useful information. It should be expanded if it can be related
to the Program or deleted if nothing definitive can be established,
s
Page 3-15. S. 3.054
CSS-15 C Second sentence typo, "pawfish" should be panfish.
Page 3-16. S. 3.057
css-16r It is curious to note that the Canadian commercial
fishery took 80% of the 19.5 million lbs. by harvest in 1977
while Canada successfully extracts natural gas from beneath
the lakebed. A comment on the compatibility of the two natural
.resource management efforts is appropriate.
Page 3-47. S. 3.130
CSS-l7f" This section does not say anything about the price
elasticity of substitution of natural gas with other fuels.
Also, this section does not indicate the energy efficiency and
environmental benefits of natural gas compared to other fuels.
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oomments/157
-5-
Page 3-47. Table 3-13
This table does not utilize any FERC (government)
or American Gas Association source documents in order to deter-
mine natural gas deliveries and curtailments to the various
counties in the study area. This federal agency and AGA have
published voluminous comprehensive and accurate data on the
^subject.
Page 4-11. Table 4-5
' Under the heading "Activity: Release: Raw Natural
Gas," a figure of 50 rag/1 is quoted from Cleland and Kingsbury
(1977) for freshwater Aquatic Life Criteria. It should be noted
that the solubility of methane (the dominant component of natural
gas) in water is quite low. Also, it should be mentioned that
natural gas at concentrations which can be attained in water is
not toxic to fish although during ice-cover conditions oxygen
could be displaced by methane or used in oxidation processes (see
Welch, H. E. et. al., 1980 Limnol. Oceanography 25(1) 100-113.).
Also, an unpublished report of toxicity tests of natural gas on
rainbow trout (Salmo gairdneri) indicated no fish mortality or
acute toxic effects on rainbow trout in natural gas-saturated
water as long as oxygen concentrations were maintained in the
test aquaria, (Toxicity Tests of Natural Gas) (1977) Unpublished
Report. Foothills Pipeline Limited, Alberta, Canada.
CSS-20
Page 4-23. S. 4.061
' The "reef-effect" of offshore rigs should be
mentioned. There are several publications (See Dugas,
et. al., 1979. Oil rigs and offshore sportfishing in
Louisiana. Fisheries. 4(6). 2-10).
CSS-21
Page 4-57. S. 4.157
" This section fails to indicate that the availability
of natural gas to this region could possibly stimulate economic
growth. This section also fails to point out that since the
region's infrastructure presently has an ingrained familiarity
with gas industry activities, this would be a plus for the
region's job market. This section fails to point out that
large quantities of steel and other requisite construction
materials needed for U.S. Lake Erie natural gas resource de-
velopment are already in place in the region and thus should
-------
i.omments/158
-6-
CSS-21
CSS-22
CSS-23
CSS-24
help the region's economy which is presently in a cyclical
downturn phase. In sum, the economic productivity of region
will be enhanced by the availability of this new energy source.
JThese concepts must be included in any socioeconomic discussion.
Page 4-65. S. 4.190
^ This section should spell out in some detail the
significance of this project on the current U.S. dependence
on foreign oil and the unfavorable balance of payments de-
ficit which the Nation is now experiencing.
Page D-9. S. D.035
' Natural gas liquids are a valuable and important
source of hydrocarbons, having many significant uses including
less dependence on foreign sources. In addition, they can be
transported to shore in the gas pipeline. The gas industry has
considerable experience (Gulf of Mexico and onshore gas fields)
in handling the liquids and they pose little, if any, impacts
different from natural gas production, processing and transporta-
tion. The impacts of these liquids are substantially less than oil.
This proposed requirement should be eliminated as
wasteful, inefficient and depriving the country and states of
an important source of hydrocarbons and natural gas. Why such
a requirement would be imposed is not discussed. In any case,
such a requirement is irrational and wasteful of hydrocarbons
^and economic resources (see pages 1-21, 1-39 and A-9 to A-10 also).
Page D-ll, S. D.039
~
The first requirement for drilling fluids, comple-
tion fluids, spent acid and drill cuttings was probably imposed
because of proposed hazardous waste regulations. However, these
wastes are excluded as hazardous wastes by the promulgated regu-
lations (Section 261.4(b)(5)). This requirement will be expen-
sive and, in light of the regulations, is not needed. At most,
it should be limited to those wastes meeting the characteristics
of a hazardous waste (Subpart C of 40 CFR 261). It is recommended
that this section be revised to comply with USEPA's present hazar-
dous waste regulations.
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i.omments/159
-7-
CSS-25
CSS-26
CSS-27
CSS-28
Columbia objects to the Corps' proposal to require
automatic across-the-board plugging of oil, natural gas and
condensate wells that experience any degree of loss of con-
trol. Columbia believes that well drilling technology has
developed to a point where such wells, in most instances,
need not be plugged whenever the reason for loss of control
is corrected. The decision to plug such a well must be made
on a case-by-case basis after due consideration is given to
kthe cause of the loss of control.
The Corps' proposal to mandate plugging natural
gas wells which "...indicates a production potential of 5
gallons/day or more of natural gas liquids...." is also ob-
jectional. Natural gas liquids are generally made up of
hydrocarbons which are a vapor (e.g. propane, butane, ethane)
at standard conditions of temperature and pressure. Natural
gas liquids might also include some light hydrocarbon liquids
which when released to ambient conditions, do not vaporize
immediately but will evaporate quickly. Thus, the need to
plug such wells is seriously questioned. Therefore, Columbia
recommends that the Corps delete this requirement from its
sFPEIS.
' Further, the DPEIS defines oil and condensate as
"liquid hydrocarbons." This is incorrect and should be corrected.
Oil or crude oil and condensate are two completely different
classes of hydrocarbons. A distinction must be made between
^these liquids in the DPEIS.
' In conclusion, Columbia would like to point out
that environmental protection through legislative mandate has
resulted in pollution control practices and an environmental
awareness which can assure the goals of NEPA, the Clean Water
Act, the Clean Air Act, the Endangered Species Act and the many
other related laws which deal with natural resource protection
and conservation. Columbia recommends that the Corps and others
rely on this body of environmental legislation and the regulations
and permitting programs established by such legislation for making
a determination as to whether activities should be permitted or
prohibited in the drilling of Lake Erie. Thus, Columbia recommends
that the Corps look to these in-place programs for assuring that
emissions, discharges, etc. will not impact the environment in-
stead of establishing arbitrary categorical prohibitions.
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comments/160
-8-
In general, Columbia agrees with the general con-
clusion that the Corps has reached in its DPEIS--that develop-
ment of Lake Erie energy resources will not significantly
affect the environment and therefore is environmentally
acceptable.
' Examination of the Canadian experience in Lake
Erie natural gas development indicates no serious pollution
incidents since this program began in 1913! Given this
Canadian precedent, the highly structured environmental con-
trol regulations and the advanced technologies which have
responded to new pollution control standards, we too,believe
that energy resource development in Lake Erie and its onshore
areas will not significantly affect the environment. In view
of the Nation's urgent need for energy, this Development Program
is, in our opinion, essential.
Yours very truly,
RWWJr:rmc
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Comments/161
LEAGUE OF
WOMEN VOTERS
5731 2aranor Drive
Kent, Ohio kkZkO
January 10, 1931
To 1
Proms
Res
Col. George ?. Johnson, District Engineer, 3uffalo District, Corps of Engineers
1776 Kiagara Street, 3ufi'alo, HY 14207
Edith Chase, Natural Resources Director
Comments on Draft Programmatic Environmental Impact Statement related to
U.S. Lake Erie Natural Gas Resource Development
LWVO-ljThe League of './omen Voters of Ohio believes that between now and the ye..r 2000, while
arriving at long-terra energy strategies, the U.S. should develop and use a mix of energy
sources bssed on the following policies 1
-Top priority must be given to conservation; renewable resources, especially solar
heating and cooling, bioco-version and winds and the environmentally sound use of coal;
-Dependence on inported energy supplies must be reduced1
-Because finite supplies of domestic oil and natural gas must be conserved, reliance
on these sources should not be increased.
3eyond the year 2000, the U.S. should rely predominantly on renewable resources.
LWV0-2]The League of '/omen Voters of Ohio has long been concerned about drilling for oil and
gas in Lake Erie because Lake 2rie is the only source of drinkln-T water for over half
of the 11 million residents in the Lake Srie Basin. Neither oil nor brine from drilling
activities can be remove- from drinking water by treatment plants at present. In the
event of a spill, no alternate sources of supply are available because groundwater
supplies are very United in northern Ohio. A major spill associated with drilling
would wash ashore and despoil beaches and seriously affect fish and wildlife.
We commend the Corps and Uij3?A Region V for a comprehensive Snvironmental Impact State-
ment that focuses on the questions can U.S. Lake Erie natural gas be developed in an
environmentally acceptable manner? Several comments 1
LWVO-3] Drilling should be permitted only if the most nrotectlve technologies are used (pa-e 1-7),
Including waste management,
!fe a^ree that hydrogen sulfide is a toxic and corrosive ;^as (p. 1-22) and must be
maintained below toxic concentrations while drilling and must V removed from the -as
^tream at shore. High concentrations are anticipated in Ohio Lockport reefs (0. I-50),
J*
LWVO-4|'.re arrree that production of no liquid hydrocarbons is impractical but sho Id be held to
a minimun (p. 1-23). Therefore stringent precautions must be taken to prevent contamina-
tion of drinking water supplies with the. <5 toxic substances. Even so, accidents occur
and provisions must be installed in water treatment plants for removal of con-.anin.ints
when present. Who will pay? Additional organic contaminant?, should also be avoided
because chlorinatir.n at water treatment plants may yield carcinogenic compounds in
jirinkinT water.
\
We a^ree with the prohibition of year-round >irlllinr (p. 1-25).
We agree with the list of offshore sensitive areas (p. l-30)« dredje disposal sites,
sand and gravel resource areas, nearshore buffer zone (1 mile), and but;'er sones near
65 South Fourth SI • Columbus, Ohto 43215 • 614-469-1505
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Comments/162
LWVO-5
LWVO-6
LWVO-7
LWVO-8
physical structures and state or national boundaries. Shipping lanes should also be
"protected. Is C.5 nile fron water intake :)ipes sufficient to protect water supplies?
For example, on June 15, 1976 a blowout fron a gas well in the Gulf of Iiexico burned
like a giant bio-.torch for two days. The condensate, a li^ht oil-like mixture, spread
over a 12-mile lon;--' and 1-mile wide area. Criteria for issuance of permits should also
include consideration of winds and currents. The map, Figure 1-1, does not provide a
buffer zone around the Cleveland water intakes, up to 6.1 kilometers fron shore (p.3-1?)!
please correct. It should also be noted that this is a seismically active area and the
,depth to bedrock ranges to 500 feet.
The extensive list of references does not include CLEAR Report #132. Daniel Michael
an.i Charles Herdendorf, "Anticipated Environmental Impacts related to the Development
o"f Natural uas and Oil in the U.S. Waters of Lake Erie," a significant omission. The
authors point out that when methane degrades, it could contribute to anoxic conditions
in Lake Erie. This issue needs further investigation before drilling is permitted.
fi large variety of toxic chemicals are used in development and production from gas wells.
We agree with emphasis on compliance with all state and federal regulations on hazardous
wastes. However, AGRA regulations are still being developed and may be further affected
by Congressional action on drilling fluids, produced waters and other wastes associated
with production of oil or natural gas. Federal and state regulations on hazardous wastes,
subsurface Injection, and salt brine disposal must be in effect before permits are
issued. The SIS points out the lack of hazardous waste management facilities for dealing
with the quantities of wastes that will be produced. The "resent availability of suitable
landfills in the survey re ion is severely limited (p. 1-85). Adequate financial support,
trained nersonnel, and coordination with Safe Drinking '.later and other programs must
,al3o be prereciui3ites.
fioastal gone management programs must bf in place in each of the three states, with
LWVO-9
adequate financial supnort and nersonnel for implementation before any hermits are
issued. The ten or so landfalls and gas treatment facilities will have a major land use
impact on the shore zone, as well as potential erosion. Valuable coastal environments
may be seriously damaged by oil spills or other offshore-related pollution. Coastal
wetlands, marshes and estuaries have been found to be twice as productive as fertile
farmland. They provide Important habitat for many species of fish and shellfish, and
food and nesting places for waterfowl and other birds. Although these ar-as can purify
themselves when moderately polluted, serious and repeated pollution could take a long
time for repair, or in sone case.", damage may be permanent.
,_n Occidents and sollls are inevitable. The most effective means of coping with spills is
LWVO-10
prevention so surveillance and enforcement programs must be funded and staffed. Con-
tingency plans and spill prevention control and countermeasure plans must bs in effect
and kept up to date. All efforts must be made to recover expenses and damages from
those at fault. However, the public will probably ray in case of major accidents and
ecosystem damage. It is hard to push concepts of liability and responsibility where
bankruptcy can be used as an escape hatch. Per-barrol taxation is one way to deal with
^his problem; further investigation is needed.
NE3D
He commend the Corps and EPA for identifying assumptions made. As is cle-rly stated
oft page 1-3, prerequisite for comparison of alternatives is a clear definition of the
purpose and need for the proposed action. The EIS has hypothesized purpose and need
but the need for Lake Eric gas development has in fact not yet been established. The
Seotemb r 1978 Argonne National Laboratory renort. "An Examination of Issues Relnted to
U.S. Lake Erie Natural Cias Development," aiscussed the need for natural gas in this
region. However, passage of the Natural Jas Policy Act of 1978 abolished the dual market
system for Interstate and intrastate s;asi new ^as will be completely deregulated in 1985.
This means that curtailments as in 1976-7 should not recur. In addition the fowerplant
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comments/163
jLWVO-11
LWVO-12
and Industrial Fuel Use Act of 1978 encourr.ges Industry to switch from oil and gas to
domestic fuels such as coal, plentiful In Ohio. Fuels are, of course, not completely
Interchangeable and natural gas is essential for glass and machine tool Industries and
for feedstock. However, if "a perception of plentiful and sustained energy supply Is
an important Prerequisite for regional industrial stability and growth" (?. 1-5),
Ohio has plenty of coal!
Ilisrnatiyss
LWVO-13
lLWVO-14
The fact remains that natural gas Is a finite resource and conservation is essential
while we convert to renewable sources of energy. Conservation is briefly mentioned In
the SIS but deserves far more attention as an energy source. Sopnisticated buyers
(public and private) now routinely consider life-cycle costing, recycling and reuse,
and energy-efficient equipment. The Harvard Business School, Energy Future (Stobaugh
and Yergin) reports that (p. 133-7, 301) If the U.S. came to make a serious commitment
to conservation, It might well consume 30 to 40 percent less energy than It now does,
and still enjoy the same or an even higher standard of living. That saving would not
hinge on a major technological breakthrough, and it would require only modest adjustments
In the aay people live. Moreover, the cost of conservation energy is very competitive
with other energy sources. Conservation may well be the cheapest, safest, most produfc-
tive energy alternative readily available in largo amounts. By comparison, conservation,
is a quality energy source. It does not threaten to undermine the international monetary
system, nor does it emit carbon dioxide into the djhosphere, nor does it generate problems
comparable to nuclear waste. And contrary to the conventional wisdom, conservation can
stimulate Innovation, em .loyment, and economic growth. U.S. Congress, Joint Eco.iomlc
Committee, "Creating Jobs Through Energy Policyj" Hearings 95 Cong. 2 sess. (p. 28-39):
One of the most detailed efforts to investigate job-creating potential of various energy
sources was carried out for Lone1 Island. Over a 30-year period, the conservation and
gol;vr package created 178,000 jobs!
The statement Is made (SIS, d. 1-8) that the Onl-mJ Alternative Program is not expected
to be chosen In preference to the Reference Prorram. However, the Ohio self-help program
Is deemed a success ,p. 2-3). fiecent drilling records i,p. 2-2) show that onland drilling
activity is significantly incr^asin^ and additional supplies are beln.; found. The pro-
blems In Ohio are appreciable—including Improper disposal of formation waters, delays
and Inadequate reclamation of sites, and inadequate staff for inspection—and do not
Juild confidence in operation of any offshore program.
S
Co^eneratlon and solar have scarcely been considered but significant amounts!of energy
can be obtained with "heve-and-now" technology. While coal gasification is still being
lLWVO-15
developed (CCiiGCO has a pro losed Project in ilobls County;, coal se.^.m methane gas should
be further investigated. Kuuskraa et al (Recovery of Unconventional Jas, Vol. II,
U3D0E, 1978)—note on pa^e 2-10—estimates that about 80 billion cubic feet of methane
^s vented each year fron working Appalachia mines.
Purpose
The statement is made (p. l-l) th.t Lake Erie gas has never been vie veil as the answer
to natural gas supply problems by regional gas-user Indusirles. fhe purpose of lake
Erie gas development is defined (•). 1-5) as an attennt by New York, Pennsylvania, and
Ohio to provide a more secure regional natural gas reserve base, to provide flexibility
In supply sourcer. for gas utilities and large industrial gas users. However, the price
nay be high and quantity Halted, ihe 1975 Clifford renort, Chio JPoloTic;il Surv-y,
estimates that I&ke reserves co'ild suoply only one -ercent of Ohio's needs at naxinum
production. Even if two percent is obtained, are the benefits worth the risks?
X313
LWVO-lt
Based on the Reference Program, the rica oP lake Erie natural gas Is estimated at
52.47/milllon Stu In 1980 (p. k-6U). A letter to me from D. D. McLean, Supervisor,
Petroleum Resources Section, Ontario Iilnlstry of Natural Resources (Kay 15, 1975) • stated
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Comments/164
LWVO-16
LWVO-17
that "we estimate the cost of drilling In Lake 2rie to be approximately four times that
of drilling on land. This would include drilling and fracturing the well and laying
the satherlnT lines to shore." The issue of costs needs further investigation and must
include waste management. If the purpose of Lake 3rie zas development is for consumers,
we will bs buyin;; expensive gas and nayin; the ^ billion (p. 1-109; to the State of
Ohio. If the purpose of Lake 2rle r;as is for large industrial gas user^, will increased
energy costs put these companies at a conpetitlvo; disadvantage compared with those in
other states?
oi^nific^nt amounts of annual state revenues ars estimated (p. 1-109). Possible economic
benefits must b>* weighed, however, not only against potential harm to the Lake, but
also a-ainst cost of surveillance and enforcement, administration by all a;=noies involved,
anc" cleanup of spills and eontanim-.tion of water supplies. Investments in pollution
abatement Dro,-;rams costing municipalities and industries millions of dollars nay also
be jeopardized.
LWVO-18^0 summarize, I recommend that, before a decision Is made to proceed, further investi-
gation is needed for buffer zone boundaries, methane degradation in Lake 3rle, hazardous'
waste management, coastal zone impacts, financial responsibility, costs, need and
alternatives.
LWVO-1
(Conclusion»
We appreciate efforts made by the Corps and U3EPA to involve the public,
incl::din": conies to interacted parties and libraries. Because discussion of need in
the 1978 Ar^oais report was" based on conditions now obsolete and because so many oeoole
would be affected by Lake Erie g;is development (water sup ly, waste management, costs),
I request a public hearing to discuss these issues and alternatives before a decision is
made or a regulatory Task Force is created. As an alternative, I request a responsive-
ness summary, with a summary of the public's views and significant comments, and the
agency's specific responses (Federal Se.Tlster. 16, 1979, p. 10296). ihank you
for this opportunity to express our views.
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Comments/165
SHARON AUDUBON CENTER, ROUTE 4, SHARON, CONNECTICUT 06069
203-364-598?
January 12, 1981
George ?. Johnson
Colonel, Corps of Engineers
District Engineer
Department of the Army-
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
Attention: Regulatory Functions 3ranch
Dear Colonel Johnson:
The Regional Office welcomes the opportunity to comment on the draft program-
matic environmental impact statement entitled "U.S. Lake Erie Natural Gas
Resource Development."
In reviewing the draft EIS we were concerned with two areas: contingency plans
for oil spills and the disturbance of sediment with the potential for re-
suspension.
The accident contingency plan appears to be quite comprehensive with the
over lapping national, regional, and state programs. We hope that the pro-
posed regulations for the National Cil and Hazardous Substances Contingency
Plan will become finalized before the final EIS is issued. We understand
that these regulations will also have an effect on the Great Lakes Region
Oil and Hazardous Substances Contingency Plan and may also have an impact on
the National Response Team as well as the state Cil and Hazardous Substances
Contingency Programs.
It would also seem appriopriate for the EIS to address the precautions being
staken to prevent spills.
''The disturbance of sediments and the subsequent resuspension of substances
such as heavy metals is difficult to gauge. Lake Erie is a complex body of
water because of depth, currents, and weather conditions. The EIS conveys
the impression that the disturbance of sediments would be minimal and the
likelihood for resuspension of heavy metals limited, ne sincerely hope that
this assessment is accurate in view of the activity of the rig, tug, and
barge in the 5 to 10 days that is needed to drill and complete the well,
and during trenching and the laying of pipe.
AMERICANS COMMITTED TO CONSERVATION
Connecticut • Maine • Massachusetts • New Hampshire • New York • Rhode Island • Vermont
-------
i.omments/166
Geosge ?. Johnson
page 2
s
It is interesting to note that on 3-19 it is stated that Lake Erie is highly-
buffered, and that on E-9 it is stated that lake ecosystems have been altered
by acid rain. We wonder if increasingly acid conditions in Lake Erie Fight
lead to an increase in the resuspension of heavy metals as has been the case
in smaller bodies of water where the acidic conditions have been studied
intensely.
Sincerely,
Marshal T. Case
Regional Representative
cc Gregory H. Sovas
Chief, Bureau of t-ineral Resources
New York State Department of Environmental Conservation
50 "wolf Road
Albany, New York 12233
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comments/167
League of Women Voters
LAKE ERIE BAS5N COMMITTEE
I
JANUARY 12,1980
BUFFALO, NEW YCRK
SUBJECT: DRAFT IR0GR AMMATIC ENVIRONMENTAL IMPACT
STATEMENT: U.S.LAXE ERIE NA1URAL GAS RESOURCE
DEVELOPS T
^ The Lake Erie Basin Committee of the League of Women Voters represents
7800 members in the Lake Erie watershed areas of Michigan,Indiana,Ohio,
Pennsylvania and KewYYork. Since its inception in 1963 this committee
and its component Leagues have worked to protect and restore Lake Erie
and its tributaries through pollution abatement and prevention ,and
through improved planning and management of water and related land resour-
ces.
Over the years the LE3C has been active in promoting programs that are
beneficial to the Lake Erie Region ,such4T.lmitation of phosphates in
detergents,tertiary treatment for municipal wastewater facilities,flood
plain management programs through proper land use and planning and flood
insurance,support of beverage container legislation and support for
hazardous waste programs to control toxics at their source by reduction
of these vastesfirst,recycling and reuse and proper disposal of those
wastes that cannot be reused.
Members throughout the Basin have been active in 308 water quality pro-
grams .watershed studies in the Western basin .Coastal Zone Management
and shoreline erosion studies and dredging and filling. Lake Erie Basin
Committee steering committee members were representatives to the Inter-
national Joint Commission Pollution From Land Use Activities Reference
Group public consultation panels and are well aware of the uses and abuses
of Lake Erie's waters and adjoining lands. Years of experience with Lake
Erie water quality issues have proven to us that prevention of an unneces-
sary activity is the best way to protect our water resource.
Remedial neasures after the damage has been done are always more costly
and risk the health and safety of the public. Western New York has more
^than its share of hazardous waste and radioactive waste problems.
S Ihe quality of our drinking water is directly related to .the quality of
our life. The lack of association ,the failure to recognize a: common lnteiw
est in the total water supply/waste treatment cycle creates a public
health problem that grows more critical day by day as new hazards are
discovered In our drinking water. What is known is that many organic
chemicals are persistent in the environment,toxic at extremely low con-
centrations ,may have synergistic effects or undergo metabolic changes
increasing their threat to man and the aquqtlc community.
Hie Great Lakes are the primary source,In some Instances the only source
of domestic water supply for over thirty million residents in the United
States, mis has been defined by the International Joint Commission as
"the most sensitive use " of the Lakes waters. The majority of the resi-
dents from the Western New York ,Erie/Kiagara Region depend upon Lake Erie
and the Klagara River as their prime source of drinking water* Groundwater
MICHIGAN . INDIANA • OHIO • PENNSYLVANIA . NEW VORK
-------
Comments/168
'uss^e.in the bi-couuty' -;ren' iccounts for only ten' pcrc-ent of the total
"water used lor domestic purpose supplied from individual ind municipal
wells •
?5 water Intake lines extend Into Lake Erie from Ohio's shores,Cleveland'3
water lines extend Amlles into the lake and cover an grea of 130 square
jnllea,providing water for ovp" 3 million people In 72 communities.
Development of mort: chemical substances and new uses for old substances
add to the growing volume of possibly hazardous contaminants put into
W3ter that must be purified to drink.
The chlorinated hydrocarbons form a highly diverse group unified only by
the established practise of consolidating effluent data under a single heal
lng. Sources of waste streams are diversified since these materials are
used as solvents ,extractants and heat transfer agents. Ihey are used as
starting materials In the manufacture of resins and plastics and a wide
range bf substituted (but non-chlorinated) organics. In addition there is
evidence that they are formed at the sewage treatment plant and the water
supply facility by the action of chlorine gas on various organic contamin-
ants. Kany highly toxic materials are resistant to bi©degradation. Many
contain both polar and lipid soluble. Ihese forms remain In solution in
lakes and rivers until they eater the food chain. Within the animal these
compounds are reconcentrated In the fat of higher forms. The bio- concen-
tration in ilsh and water fowl la well documented.
In addition to the problem of toxleity,( Source; USSPA)chlorinea hydro-
carbons have potential carcinogenic,terratagenic and mutagenic properties.
People.unlike laboratory animals,are exposed to more than one carcinogen
in their everyday lives and through the interactions of body chemistry, •
exposure to a variety of carcinogens can be cumulative. No dose of a car-
cinogen,no natter how small,can be relied on to be safe for every individual..
Contrary to what much of industry would have people believe,the concept cf
a' "threshold 'br *ho effects " dose has no practical validity. Even what
scientists call a " weak " carcinogen can lead tomany thousands of cancers
11 hundreds of millions of people are exposed. And the earlier the exposure
begins and the longer it continues the greater will be the risk,whether
.doses are large or small.
The 1978 Water Quality Agreement between the United States and Canada:
Article I defines "loxic substance means a substance means a substance which
can cause death",disease,behavioral abnormalities,cancer,genetic mutations,
physiological or reproductive malfunctions or deformities in any organism
or its offspring or which can become poisonous after concentration in the
food chain or In combination with other substances."
Under Annex I specific objectives have been set based on available inform-
ation on cause /effect relationships between pollutants and receptors to
protect the recognized most sensitive use in all waters. Objectives have
been specified for organic chemicals;pesticides aldrln/dleldrln,chlordane,
CQt and metabolites,endrin.heptachor/heptachlor epoxide,lindane.methoxychlof
mlrex and toxaphene and other compounds phthalic acid esters and PCB's. Fcr
other organic contaminants for which objectives have not been defined ,but
which can be demonstrated to be persistant and are likely to be toxic, the
concentrations of such compounds should be substantially absent less than
detection levels as determined by the best scientific methodology availably
The intent of programs specified in Annex 12'Persistent Toxic Substances
is to virtually eliminate the input of persistent tcxlc substances in ord«r
to protect human health and to insure continued health and productivity of
living aquatic resources and man's use thereof; The philosophy adopted for
control of Inputs of persistent toxic substances shall be zero discharge.
The Intrenatlonal Joint Commission has Jurisdiction over boundary waters
and Great Lakes pollution embodied in two treaties and special expertise
In the management of boundary waters by its investigatory function. The
signing November 22,1978 of the Great Lakes Water Quality Agreement re-
affirmed the U.S.-Canada determination to restore and enhance water quallly
in the Great Lakes System under the rights and obligations of both countr
-------
Comments/169
uncer Uic Boundary Waters Treaty of 1909 pnrtlculnrly the second part of
Article IV of that Treaty which prohibits the pollution of boundary waters
and water flowing across the boundary on either side to the Injury of heali
or property on the other. The prohibition is absolute,contingent upon no
additional circumstance to make it obligatory; the provision is therefore
self-executing. The Treaty does not require a Canadian citizen to press aiy
claims under Artlclell or Article IV before the IJC prior to bringing an
action in a United States court. Under Article VI of the U.S. Constitution
treaties are the supreme law of the land.
The Lake Erie Basin committee has long respected the international Juri>
dictions in Great Lakes water quality decisions as Important to the health
and safety of citizens on both sides of the United States -Canada boundary
and place the highest priority to preserve this irreplaceable water resource
from further degradation.
Although there is a brief mention of the 1978 Kater Quality Agreement in
4.017 it is not included In Appendix D Summary of Existing Rules and Regul-
ations and proposed guidelines that may be used to define an Acceptable
Offshore Katural Gas Development Program in the U.S. Waters of Lake Erie;
Does this mean that the 1978 Water Quality Agreement objectives will not to
used as a guideline for standards and required, practises in the proposed
program ? Th6.word may indicates in'legal terms: you may.or-may not. It
show3 uncertalnety as f.o-Just What standards will be used. The Draft snovs
missing data for standards which leads to questioning if It islan. environ-^
^entally safe program.
/ An environmental Impact statement is supposed to focus on five issues ;
potential environmental impacts,unavoidable adverse impacts,Irreversible
impacts,short-term versus long-term resource use considerations and altern-
atives to the proposed action. This Draft is deficient in all of these araaj
particularly the unavoidable adverse impacts,irreversible Impacts and short
term versus long term resource use considerations.
The Lake Erie Basin Committee believes there is no need for the proposed
gas development in Lake Erie. Most data used to evalute the proposed refer
ence program are based on selected extrapolations of insufficient 'inform-?-,
ation.
S Curtailments of gas during 1975-77 and 1977-78 winter periods were caussd
by distribution problems and lack of storage capacity. Changes in'"pricing
policies and regulations released gas for public distribution and encoursv
ed even more the extensive land drilling operations that had been increasing
during the 70's. Fears of shortages and price escalations have encouraged
industries.municipalltles,institutions and school districts to drill their
own wells. Over 100 lndustrltries in Ohio have taken advantage of this self
help program.
Kith this statement the LE3C is submitting a most recent report by the
American Gas Association entitled "The Gas Energy Supply CXitlook; 1980-^
3D00 dated October I960. Its estimates'of proven reserves Indicates there
is no need to risk our water supply#
"y Seismic information is incomplete • Enclosed Is an e^rthouake hazard inso
which shows an error1was made in the Lawler,Katusky end. Skelly-report"to¦""
the ivYS lerislsture. In comparing the maps it shows that a b was inserted
where a 9 is in the original by the National Oceanic and Atmospheric Adm.
fnis is a prime example of how missinform9tion is preserved in perpetuity.
Over thirty earthquakes ,of several origins end of relatively high intensity
(KK5-I3), have been recorded as affecting northeastern United States andtine
Lake Epie Basin. Canadian earthquake information shows an epicenter In
Lake Erie off Presque Isle .There-isia past.- history.of activity in the
¦ Erle,Penn.. „« i_
^ The proposed tuldelines call for closed systems with 7ero discharge
however the drill ship operation Is an open system where contaminants ,
drilling muds and cuttings would go Into the Lake. Sediment Is a primary
concern becsu9e of its ability to bind phosphorus .heavy metals,pesticides
end other organic compounds(such as PC3's. IJC PLUARG has determined
-------
comments/170
jji ^
that these materials cnn becomevto clay sl7e fraction of suspended solids
( .<2 u m particle size and move easily with water. These pirticlcs settle
out very slowly when they reach the open lakes. Their large surface area
and slow nettling rate cm expose the clay-particle associated pollutant to
the lake water for an extended period of time. This may allow the pollutant
to be released into the water column and become available for biological
uptake. Contaminated sediment may be physically transported long distances
before coming to a sink. With highly active contaminants,this factor will
invalidate a mixing ?one concept,since it may well result in virtual whole
^Lake contamination,
rcp- Because of the viscosity of drilling muds they can soread through the
lake bottom killing benthic organisms. Drill cuttings smother bottom life
and can change bottom contours. Could changes in bottom contours event-
uall:< change current and drift patterns? What is the effect of recycling
phosphorus from the sediments from disturbance by the development? The
impacts of a drill ship operations in Lake Erie have not been fully
^addressed •
^ At the present time there Is considerable controversy with the OCS
operations concerning the possible effects of drilling muds on marine life.
Taking into consideration that this issue has not been resolved for CCS
operations in the Georges Bank, how can the Army Corps of Engineers and
EPA Region V determine that it .will be environmentally safe In drinking
water supplies or have no effect on aquatic life in Lake Erie? These
contaminants are accumulative and represent greater risk in smaller water
j?odles. ( Telephone contact with U SEPA Wash.)
S Ihe Draft does not provide information about health risks associated
with exposure to the public of heavy metals,organics and new toxics being
Introduced Into the Lake environment. Even trace amounts of contaminants
added to the existing ones could have a synergistic effect more toxic than
the original. There Is not enough data about bioconcentration of toxics
«pither by ingestion of the lake water or the food chain >
' if a Task force will be responsible for ultimately defining a minimum
set of federal standards to guide offshore development activities thsn
the so called reference program is uncertain. Ihe identity and importance
cf many hazardous substances are not known: establishing such data must
precede a control program. The standards that will be develope.-' could
yCt.snis the risks and cost/benefit analysis.
^ Ihe location of the tests conducted by the Argonne National Lab. of
tne drilling setup and process by Canadian drillers is suspect because
of Its location. Currents are different and sediments are heavily
polluted on tne U.S. side of Laice Erie so data is insufficient to Judge
parameters for the reference program. The original drilling regulations
proposed for Lake Erie by the old i»YS Conservation Dept. in 1968 gave a
distance of l/2 mile from water intakes. The reference program proposes
„¦the' same distance no improvement bh safety from 12 years ago.
¦" Water supply cost issues have been omitted with the assumption that there
will be few accidents and/or problems occuring. from routine activities.
Tnls is unrealistic because industry officials have always always comm-
unicated to us that guarantees of no accidents cannot be given. The i»sw
York State Health Dept. published a recent report "Organic Chemicals and
Drinking Water "March 1900 which has some preliminary figures on Cost
Assessments of Control Techniques for water filtration plants. The Draft
neglected the cost of finding a replacement of our water supply or repairs
and adjustments to present systems. The water facilities could be impacted
either collectively from a large oil spill or slntly from a smaller
accident • Cll ruins sand filters in waiter nitration plants. IUrbldity
causes wear and Interferes with disinfection . Salt would have to be
taiet. out with desalination equipment which present water facilities,
do not have. How costly will it be to water supply facilities from
potential damage from contamlnants.oil salt 2 CXir water supply is the
-------
comments/171
°2 llong-ter:r. resource use of Like Erie's w- Lars .and of fJrime Importance
talsirice groundwater resources of quantity ^nd quality ^re not sufficient lor
3 Lthe population in Lhe b-isin
S Accident response pl->nn -.re inadequate. There is no joint contingency pin
for spills. Money to clennup spills from drilling "ccijents was deleted Irca
the Superlund bill recently passed by Congress and ;;i£-ned by the President.
Local governments along the lake would have to be equipped and trained to
clean-up. Who pays these extra costs? Local property owners *re still
trying to collect damages from the oil spill in L?ke Ontario caused by
,hunan negligence several years ago.
, Tne information -ibout blow-out -preventers is mlssle^ding. 3?^ to uot cf
these valves failed to function properly in the Gulf in 1970 re
(to be continually serviced. Sometlmesai,l£ has to be set up .
/ Impacts from pipelayinc operations In the lake bottom have not been
adequately addressed. What type of burial berge would be used in the Lake?
A burial barge Is used to sink the pipe beneath the surface,usually by
displacing sediments with a high pressure Jet. Were tests done during a
plpel^.ying operation to determine sediment disturbance ? Effects on aquatic
life ? dispersion? turbidity? What are true costs of laying pipelines
in deep areas of the lake? What are the problems with steep slopes?
f Re'uetilal measures to mltigate'erosion problems where pipelines would
come ashore is an interesting inconsistency in this Draft . Piecemeal
remedial measures haven't worked on Lake Cntarlo or on the South shore of
Lake Erie. Remedial measures are a much more complex problem thnn the
Draft expressed. If it so minor a problem,why is a study funded by the
taxpayer's money being carried on by the «rmy Corps of Engineers of Lake
,»Cntarlo's shore erosion problems? |t
t.u»ntltles for tne Reference program were modeled from the .•3. Nell
the* s-nillest Jack-up rig in operation in Canadian waters so are not
necessarily representative of actual future developments in Lnke Erie.
Costs are based on this same questionable data. Larger rigs such as the
lite saver II have six legs instead of four.
-------
comments/172
5 V" rc- -re conillcts -.>itn Luc CVi iVogivai teOfcr'(;i.ic nrc-:J ci i- --t- Li <-ul \r
gli-oiicern Lh->t were determined uy m^ny hours of participation vy loc?l
ti'oris in the planning process.
7 f' •••£"• Xootrt Fiacre, ivY30EC Corim. hrs announced there will be no now
u i-i';7»rious waste facilities In ..1or Erie Counties. Where will wnstes
wjirom the drilling program be put?
2 s There sre conflicts with the Erie-Ulagara Air Implementation plan. Kost
^fof the ?jpess of non-attainment -ire on the shore (Lackawanna or unclassified
g as the waterfront. How far Jo these nor.-attainment areas extend into the
1-3
2 ~ Data on harbor facilities and navigation impacts are isufficient. A stU'^r
^ f to integrate the results of cargo transportation plans and studies for high
Mjv- = ys,railroads and water borne shipping in the Great Lakes Region is being
gj. lender taken by the Great L?d reaffirmed every two years sincp I5y.
7 f Tne Draft still does not answer our question of liovember 1,1979- KHftP
n I PLA.. S ARE cEIKG MADE TO WCVIDE SAFE PCT^bLS V.'* ?ER rCR CO-'.XUMTIE3 \.,HCSZ
SlsjKPIIES ARE 01 SUPPED CH DE31RCYED BY OIL M»D CR C«S DEVELOPMENT BCTIVITIHS7
y The Lake Erie Basin Committee reserves the rlLht to comment at a future
"i fdate on areas of continuing concern since time vas so Inadequate in wnich
g I to'.exaalne this arsft which w&fl three years in the making.
rRAi>CE3 ARCARA CCORD.
LAnE er iE s:;« co.:.'. i itei
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comments/173
V
*5 *J j,
* t iuV
v* T "»
Jkw V
A.t
TELEPHONE OR VERBAL CONVERSATION RECORD
P«» w«« of tMa form, ««o AR 340>1S; A* p»o^»n«nr ogonejr l« Th« Adjufont Coft*fol'« Qffleo.
19 Jan 81
C omments on Draft E1S: Lake Erie Gas Development Study
INCOMING CALL
Fran Arcara
League of Women Voters, Lake
Erie Basin Committee
»KR»ON CALLIO
NCBCO-S
OUTGOING CALL
»CAaoN cauuinc
PMO»C NUMHIt *NO tXTKNSION
I
{J
PQ
U
h3
"fars. Arcara advised of the following typographical errors in her letter of
comment:
page 2, line 19 : change " both polar and lipid soluble." to " both polar and
lipid soluble groups."
page 2 , first line, para, at bottom of page: Intrenational to International.
page 3, second to last para, last line: change " in the Erie, Penn." to " in
the Erie, Penn. area."
page 4, third line up from bottom of page: desalination to desa'l inization.
page 5, third full para from the top: change Mr. Niel to Mr. Neil in two lines.
DA.'4"«751
replace! coition or i rit iramcN will be usco.
-------
Comments/174
Don Keoftana
42? Sterling Ave
Angola, :i.T. li;006
Feb. 9, 19S1
DK-1
'Dept. of the Army
Buffalo District, Corps of Engineers
'1776 Niagara. Street
Buffalo, KewXorie 1^207
Attention: lir. Arthur liarks, Project Engineer
BE: BICE ED STATES 33C3?T OF US JSI3 ?C3 THE BSVSLOFlSiT 0? O^S
This statement is for the public neeting of Feb* 11, 1981
Gentlemen:
I have reviewed "the Joint environmental impact draft as prepared by tha
ixtny Corps of Engineers and the U.S. Environmental Agen;y, Region V.
I cccjiliment the two agencies on the 39 month study.
& vast collection of engineering and environmental data.
The draft contains
As I see it, we are dealing with two distinct natural resoursss. Che
W.TER; two GAS. The water we have at our finger tips. The gas is some-
what evasive • 6Se a long torn natural resourse,. if we continue to protect it.
Two a short terra extraction, with the possiblity of water pollution, ir. the
process. The water we have represents the greatest concentration of open
potable water in the forty-eight states. During the past eight years ire have
retrieved a polluted Lake Erie to its natural beauty. This project cost the
nation millions of dollars and we should not jeopardise this long tern invest-
ment for a short tern. gain. I favor keeping I£ke Srie a prime natural res corse.
I,elso, f?vor the drilling for the gas reserves frosi the land.
-At this time I wish to bring to this meeting's attention the August l?3o
edition of the "EATICAL GL0G?i-FIC" magazine's feature article "-.SISS OUR HOST
PR2CIC3 EE30rJRS2" by Mr. Thorns Y. Canby. The Editor, Gilbert Grosvencr, address-
es the importance of this commodity in an. editorial in the sane issue.
I, also, want to bring to the concerned agencies attention two articales
that appeared in the 3U7?1ZC ITES'O IC.'S on Sunday, ?cb. l,l?3l. One- "TIE
THIRST for '.H.TES 30..'S!t by John Cpiej the other ortical- "The GR£-.X LMGS a
BGi&IEA THAT 2 T be t^ZSr^D" by Paul lie Clennsn.
^land.
I favor keeping Lake Srie as it is and I favor drilling for gas from the
Thank you.
Sincerely,
Don Keoliane
*1
copies to: Senator Daniel Mcynihsr.
Representative Jack Kemp
U.S. 2fcvi533=ental Protection Agency, Region V
Hew lork State Insiranmental Commissioner, Robert Hacks
Surf
CSCtisor Adella Cook, Tcm of 2vans
rie^&chardson, 3.C.L. Dist. 19
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Comments/175
C0MM3BTS C0NCSRNIN3:
DRAFT ?E&jRAf.iMATIC ENYrnONi-fSUTAL G1?.\Cr
STATEMiNT: U. 5. IAXH EJUS IIATUHAL
OAS RESOURCE DSVSLOfHSKT
SUMMAIff
TH-1 ^
TH-2
3.004 General
8.) As nf the fall 1980 there was a surplus of naturel gas regionally
pnd nationally, which ibbuI ted fron fuel switching, conservation measures,
Increased wellhead yriceo, and state incentives for Increased local productions.
I felj'part of the reason for implementing the above measured
( in S.004) is du9 to this nations economic "problems, os well as our
continued problems in dealicr with other energy producing nations.
8.004 states a possible occurrence of events which, to sill ted in a
gas availability crisis in 1976-1977 and from 1977-1978. However, these
event3 that brought about our past energy crisis, have drawn the government
end the public to an awareness never before seen in our country. Sue to
increased prices, due partially to the de—regule^ion of intur-state gas, people have
been forced to use the most stringent conservation measures.
Therefore, I would hope 3.004 is not meant to mislead eryone to
feeling thet a primary reason for naturel ess exploration in Lake Srie ia due to
past energy crisis. This alone is a certainly insufficient reason tolri.^
about such a complex and costly operation,
5.005
This section states thet the DBAFT SIS has been developed without
the benefit of a project advocate (applicant). It has therefore been
necessary to postulate purpose and need based on assumptions and real
information.
TH-3
TH-4
Therefore, although many conclusions may be accurate, how applicable
can the DBAFT SIS be if the applicant who must use the DRAFT SIS (actually -
Final 213) has been unavailable for consultation 7 For example, would the
Sast Ohio Gas Company ( A Division of Consolidated Natural Gas ) be
prepared to abide with all statements and regulations set forth in the DRAiT
Sis, and the Final HIS when it ia drafted T
I feel that any development of the DRAJT SIS and the Final SIS
^ should concorn the principles who are involved in .its application.
3.005 also states that the regions bordering the southern
shore of Lalce Srie is a national industrial centor, a net importer of energy
resources, ir.cldin^ natural pna. That statement is true in many vaya,
however, it points an unclear picture of what this region is actually like.
For example, this southern region (po "ticulsrly Greater Cleveland), has
suffered immensely from industrsil docay. A primary example was this -entern
migration of the Diamond Shamrocle Corporation and the closing of various tire
plants in the Akron area, „s well oo a continued decline in employment of
Northern Ohios nasoivn auto industry.
-------
The auto industry ia perhaps the most frightenair.it exanple of thla
regions declining econony, because it effects this area already declining Bteel '
industry. The mito industry in this region currently has "many auto workers out
of worV:. A spokesperson for UAH Local 1005 (Chevrolet Motor Civieion)
estimated 1150 workers out of work.
As n geologist from East Ohio Gas Company explalwd to tie, " 12 to 13
percent of the gas used in Ohio cones Cron Ohio itself. After this, utility
companies go to their other sources in West Virginia, Oulf states, and any
other source in this country which will sell their reserves. However, for
the ppit five years (5) sales of gas have dropped dramatically in this area.
Ona of the primary reasons is the economy, nnd particulnrly the steel
industry in thi^r region, which is SaBt Ohio Gas Company's stein buyer of gas. *
As if these facts weren't enough proof of e slow, tut steady, changing
econony, this regions population as n result has continually fallen since 1950.
Iron a high of 914, 000 to 1950, B76.000 in i960 750, 000 in 1970, the population
of doveland ( the states largeBt and noat industrallzed city) has now fallen
to 582,000.* That is a decline of 168,000 people in the past decade.
To aunanrlso, 3.005 should he stricken from the final Els, or at least he
made more specific. As it is now it paints a blurred picture of an
industrialized region, with is boomiiu* econoqy ell prined for natural gas
exploration. This is misleading and shield he amended prior to the
Final draft.
S.009
e.) This sostion mentions a last Force as the first step of the
Reference Program. From what S.009 states, this TbbIc Force is vitfl to the
successful inplenentation of the entire program. Hownvur, there is no nentian
of how this Task Force will he comprised. Will it he corporate representatives
from the Gas Companies, along with a few representatives fron local, state, and
federal govenentT Certainly there must he a balance of the letter, and also
enviromentelly responsible poople oust be sought to contribute to this'
Task Force.
It must he kept in mini that this body of water la not only vital to the
southern regions dwindling economy, but to the economy o; billions of
indlrlaual* In thi» regions c.i Ienrjsylvnnla, and Sew York.
Vith theso thought in nind I would hope that S.009 is clearly defined
prior to the Final SIS.
* tJOSLD ALH.CAC, COPYRIGHT 1979
HEWS?Art® ESTSBTRISSS INC., 5.*., E.Y.
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uQmments/177 -
5.012 Alterus. i.vbh
f.) Certainly, low - BOT, aediun BTU, and hi^h-IHJ, coal gasification xh-7
shculd be given a grant deal of attention airea cnel Is In nturulant aupoly In Ohio, and
Pennsylvania. Coal is vital to the liv< s of millions of people In these states,
particularly to the itinera who make their living directly from this resource.
Also, conservation measures must cor.tlnually be brought to the attention of
the public na well a-a the many businesses who rely on gas. y
3.013 »nd S.011* Waste Bla-pasal
\
Thse particular sectiono brir..; up an acute problem which this region XH-8
(and the nation in eenersl) already face, vasto disposal. Although it appears
in S.013 that the problem could be handled, this Is based on the use of current
traataent facilities, Will the current facilities be able to handle the additional
probleca presented by tkis resnurce developmentT /
She Draft SIS is quite informative and presehts^clearly most inforor-tlon
concerning the development of the natural gns resource in Le'Ke Brie. I hope that
prior tc the Final £13, that some of the questions I have raised are answered.
The most important thing to keep in mind ie, do we really need resource -
development of this t/pe In this region? Remembering the declining population, ae
well as industrys' continuing problems, I feol it would be an unwise decision at this
time.
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v,omments/178
NCLW-1
NCLW-2
NCLW-3
NCLW-4
League of Women Voters
LAKE ERIE BASIN COMMITTEE
I
I To : Draft Programatic Environmental Impact Statement
I U.S.Lake Erie Natural Gas Resources gevelotment.
From : Northwest Ohio Natural Resources Council
Western "asin Lake Erie Basin Committee - League of Women Voters
Beatrice J Waterbury 3525 Golfgate Dr. Toledo Oh kjSi.1*
I am Beatrice J. Waterbury, aicharter member of the lake Erie Basin Com-
mittee of the league of Women Voters. On this occasion, I have also consulted
with the members of pt the Northwest kliio Natural "asourcea Council, in
the absence of Dr. Hugh Gunderson , who has attended previous hearings*
I have carefully read the full text of the EIS and I found it to be very
well done and comprehensive. The engineering is beautJLfull, but I
remember from my early days of working on lake Erie, that some famous Eng-
ineer said, " that anything can be engineered , but not everything should
be", We feel that drilling in lake Erie for gas is in the latter catagory.
The League bagan its study at the time when Lake Erie was considered dead
by many people, especially the central basin which borders Ghio, the area
to be drilled . Through the years after intensive study , we have developed
a position, that the first priority for the use of lake Erie is for drink-
ing water for the millions of people living on the shore. Anything that
can be considered a risk to this quality must be viewed with considerable
care. We also fcjave come to cotisbbsus opposing gas and oil drilling in the
lake. We agree with the state of Michigan that the integrity of the waters
of the lake must be preserved. All of our positions are still supported.
Prior t)o reading the EIS , we reviewed the most resent IJC publications.
These were " Great lakes Water Quality Report", " The 1980 Report on Water
Quality of the Great lakes", the "PUJARG Report, and "perspective on
Hazardous '"^Substances in the Great lakes Ecosystem". Although water Qua-
lity is greatly improved, The remarks in the EIS 3.d»l relative to an oxia
in the central basin make one wander about its ability to absob or take
care of any uncommon wastes. To read the list of all the resonsibilities
each community must follow to keep water quality good must make us caus-
iouspbout anybther risks.
f The hazardous waste disposal rroblemis undergoingdiscussion here and elsewhere .
Too little is known and aad far too few people are aware that ever yone is
involved in it. Ohio has some very special problems in this field"and
a very poor reputation for taking care of theeffluent. This properly^
worries the States down lake from Chio. This'is a place where Public Hear-
ings must be held beforek project advocate can be given permission to drill.
All available data must be ^giverj to the public. If not hearings then other
means of letting the peoplajviust be found.
Other hazardous situations are also questionable. I thought that any
construction in the lake must be at least a mile from any water intake.
•5 of a mile is not far enough away. If the contaminant in the gas is H 2 S
there is need for extra cau^tion.
MICHIGAN - INDIANA . OHIO • PENNSYLVANIA . NEW YORK
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i.omments/179
NORTHWESTERN OHIO
REPRESENTING'. SPORTSMEN'S ORGANIZATIONS, NATURALIST'S ASSOCIATIONS, GARDEN CLUBS
YACHT CLUBS. CIVIC GROUPS, and INDIVIDUAL CONSERVATIONISTS.
NCLW-5
NCLW-6
NCLW-7
NCLW-8
Wo have doubts about the economic feasibility , not that this is not well calculated
but other projects of the kind have cost over runs." There is many a slip between
the cup and the lip." The 4.3 billion sounds very enticing to an kh area in need
of money. Opportunity for jobs is welcome, but because of the whole energy situa-
tion being in uncertainty should we take another look at growth. How should we grow/?
Shortages over the long term,of the conventional forms of energy should make us
pause before risking anything as essential as drinking water . We should look tow-
ard different energy sources.
must be sure from now on that every project is cost effective. Too many times
ill the past the money for a project fizzles.OTt^£efore the clean up has been
accomplished. We must be sure that we do not^uture generations holding the bag
for costs they probably ,1 cannot ^ay. It has been said that intervention in the
ecosystem tends to engender more intervention. "epeated ecological errors have
seldom been corrected either by those suffering frcn the results or the government.
\ remember seeing gas flairs at the comers of the farmers fields in this section
of the country. Mo doubt the gas was wasted. There are at this time many small
oil wells producing small quantities of oil . Any big effort would prove to b e
too costly. There may be more draw backs for drilling for gas on land than in
the water. But from what t read in the various reports , contaminants in the
ureat Lakes and toxic wastes head the worry list.
*the trend of projects being'fait accompli/before they are T^resanted to the public
seems to be growing. We would support any effort toward mora education and
giving of more information to the public In order to keep democracy our way of
,life.
true conservation
is
the wise use
of our natural resources
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comments/180
IlJndeawafej* (§ as Developers
LIMITED
Box 428. Port Co/borne, Ontario L3K 1B7
Telephone (416 ) 894-1731
1981-02-n
Department of the Army
Buffalo District, Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207
DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT
ENTITLED "U.S. LAKE ERIE NATURAL GAS RESOURCE DEVELOPMENT"
I would like to submit for your consideration the following comments
on the Draft Programmatic Environmental Impact Statement entitled
"U.S. Lake Erie Natural Gas Resource Development".
On page D-ll Section D.039 subsection 2 and elsewhere it is proposed
that all drill cuttings be brought ashore. These cuttings as described
on page 1-81 Section 1.108. If these cuttings are allowed to go into
the water I believe that no adverse effects will result. I believe you
should reconsider this proposal and allow the cuttings to be returned
to the lake.
All suggested drilling programs specify that all drilling fluid be contained
and recycled or brought ashore for disposal. The ideal drilling fluid for
many areas of the lake is clear water. The best way to do this is to pick
up fresh lake water, pump it through the hole once and return it to the
lake. The suggested programs will not allow the ideal system to be used and
will add considerably to the cost of drilling.
It is proposed that excess cement be collected and returned to shore. The
amount is very small as shown on page 1-81 table 1-29. I would like you
to consider whether this amount of cement would have any adverse effect
on the water.
It is proposed that sanitary and domestic waste be transported to shore.
kThis could be treated with an onboard approved sewage treatment system.
On page 1-57 Section 1.095 a barge stationed alongside the rig is referred
to. In the open waters of Lake Erie it is not safe to allow a barge to
remain beside a jack up rig or floating drill ship for extended periods.
Wave action on the barge could cause structural damage to the barge and/or
the drill rig or drill ship.
'On page 1-56 table 1-21 item 2-2.3 a caisson is recommended for jack up
rigs. In most cases I see no reason why the bottom of the wellhead
should not be placed at lake bottom and the wellhead and valve be allowed
to project not more than five feet above lake bottom.
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Comments/181
Department of the Army
1981-02-11
Page Two
UGD-4
UGD-5
UGD-6
Item 2-2.4 recommends that sixteen inch drive pipe be set when wells are
drilled with a jack up platform. Sixteen inch is an arbitrary number
and a much smaller drive pipe would accommodate existing programs. However
I question the need of any drive pipe. If a closed system is an absolute
necessity you would have more protection if a hole was drilled to the top
of, or a few feet into competent bedrock and a mud string run and cemented
at this point. This is the same as in the recommended floating rig program.
I feel that requiring drive pipe does not give you the protection you are
looking for.
Page 1-60 table 1-22 D-3 specifies a 6 1/4 inch hole drilled to total depth.
Common practice is to drill a 6 3/4 inch hole but other sizes such as 7 7/8
v inch would be common.
Lake water/CaCl2 solution is suggested to minimize dissolution of salt
zones. In many areas of the lake no salt zones are present. In this case
there is no reason to use CaCl2 in the drilling fluid or to later convert
the system to polybrine.
The above conments regarding the CaCl2 mud system apply to the drill ship
^program table 1-23 Section 0.
If a procedure does no damage or creates no exposure to unnecessary risk
it should not be prohibited. Any restriction should be carefully considered
before it is made a recommendation or requirement. Costs of operating in
a marine environment are very high. It could be very easy to put in place
a set of regulation that impose needless restriction and make the cost of
1^ recovering Lake Erie gas impractical.
I have been involved in offshore gas drilling in Lake Erie for twelve years
and make these comments only with the intention of assisting you in
arriving at safe, practical regulations for the development of Lake Erie.
R. C. Brooks
Manager, Niagara District
RCB/dmr
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Job A/LERESl/p.1
EPA-1 As indicated in paragraph two of the USEPA cover letter, the Corps of Engineers must
make a determination for each permit application concerning the need for an Environ-
mental Impact Statement (E1S). In each case, after review of the specific proposal
and its potential effects, the Corps must determine whether or not issuance of a
permit would constitute a Major Federal Action Significantly Affecting the Quality
of .the Human Environment. These determinations would be made in accordance with
Corps regulations implementing the National Environmental Policy Act of 1969 (NEPA;
33 CFR 230) and Council on Environmental Quality regulations 40 CFR parts 1500-1508.
A reasoned judgment concerning the need for an E1S can best be made when proposal-
specific and site-specific information is available and a preliminary analysis of
0
potential effects of permit issuance is made. In this regard, the Corps District
Engineer may request any information deemed necessary to make his determination on a
particular application. Although the programmatic DEIS cannot assess all site-
specific and proposal-specific effects, the need for this type of information, in
itself, would not warrant preparation of an EIS since the necessary data can be
generated by other means. Based on the analysis contained in the DEIS, many of the
impacts are expected to be temporary, minor, highly localized, and mitigable. Thus,
depending on the scope of a proposal and additional information on specific proposed
sites, the effects on the quality of the human environment may not be significant in
all cases. Rather than predetermine the necessity of an EIS for all future cases,
the Corps proposes to await specific proposals from operators and make the appropri-
ate NEPA determinations in accordance with 33 CFR 230 and 40 CFR 1500-1508. The
USEPA regional offices along with other agencies and the general public would be
notified of determinations made on each application and would be afforded the oppor-
tunity to comment.
In cases that do not warrant preparation of an EIS, the District Engineer>uo.uld
announce that a preliminary determination has been made not to prepare an EIS. a
final decision concerning the necessity of an EIS would not be made until after the
public review period was completed and an environmental assessment had been prepared.
The District Engineer could reverse his original preliminary determination if the
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Job A/LERESl/p.2
results of the public review or the results of the environmental assessment indi-
cated that reversal of the decision was necessary*. Thus, even in those cases where
an EIS was not required, the public and agencies would be advised of the proposal
and given the opportunity to comment, and an environmental assessment would be
prepared. We currently foresee that proposals could fall under one of the following
NEPA requirements, depending on the impact and scope of the proposal: preparation
of an EIS specific to that proposal; preparation of a site-specific and/or proposal-
specific supplement to the programmatic EIS; or preparation of a detailed environ-
mental assessment. Thus, although we do not believe that a predetermination of EIS
necessity for all future cases is currently warranted, we will ensure that all
applications are reviewed in accordance with NEPA.
There are actually sixteen lease areas. Lease Area XV is Lease Area XIV drilled
deeper for Clinton-Medina, and Lease Area XVI is Lease Area XIII drilled deeper for
Clinton-Medina. See Table 1-18 of the DEIS for clarification of the lease areas.
EPA-2 The USEPA is probably referring to paragraph 1.102. The circumstances under which
collection, storage, and land disposal will not occur during normal operations are
presented in Table 1-25.
EPA-3 Comment noted.'
EPA-4 There is admittedly a shortage of both sanitary landfills and RCRA hazardous waste
disposal sites in the region adjacent to the lake (and nationwide, as well). The
monitoring and regulation requirements suggested in paragraph 1.116, as well as the
exclusion of gas drilling wastes from the RCRA hazardous waste category in the
revised RCRA regulations, may minimize the need for RCRA hazardous waste disposal
sites resulting from gas drilling. In any case, however, new disposal sites—whether
sanitary landfills or secure hazardous waste landfills—must be developed. Site-
specific permit approvals may have to be contingent upon the development of a suit-
able disposal site.
EPA-5 In paragraphs 1.115 and 1.116, it is noted that the nature of the drilling fluid
additives is unknown, often because of the proprietary nature of these formulations,
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Job A/LERESl/p.3
but it is suggested that periodic monitdring or strict regulation of toxic additives
be made part of the Reference Program. Monitoring and disclosure requirements and
restrictions on the use of hazardous additives may obviate the necessity to dispose
of these wastes in a hazardous waste disposal facility. [Note that the revised RCRA
regulations, namely AO CFR 261.4(b)(5), specifically exclude these wastes from the
hazardous waste designation at the federal level. However, the states may impose
more stringent requirements. A waste may be nonhazardous in the RCRA sense and
still pose a hazard.]
EPA-6 The characterization of impacts listed in Tables 4-3 to 4-5 is based upon the exami-
nation of estimated concentrations at the release point and 0.5 mile downcurrent of
the release point, and upon comparison of the latter concentrations with drinking
water standards and criteria for freshwater aquatic life. An impact is characterized
as localized if it declined rapidly in magnitude with downcurrent distance, and
characterized as moderate or minor if its potential for impact on drinking water
quality and biological communities is considered small.
EPA-7 Paragraph 4.067 should state: "The likelihood of a gas well or pipeline being snag-
ged and broken by an anchor appears moderate. Any applicant should be required to
develop contingencies to prevent such accidents from occurring and to minimize the
impacts, if they do occur. Wells ..." See Topical Response Number 7 on Contingency
Plans and Cleanups.
EPA-8 There are ways to ensure earlier detection. The easiest method would be to install
pressure and rate sensors in the flowlines at the plant. These sensors would in
turn be coupled to alarms that would have remote alert stations where someone could
continuously monitor the alarms for the first sign of trouble. Once the problem was
located, the proper personnel would be alerted and steps would be taken to cure the
problem immediately.
In response to the question about automatic safety-valve failures, the easiest solu-
tion would be to install manual safety valves in tandem with the automatic valves.
This would ensure that the gas flow could be stopped before the three-day limit set
forth in the DEIS. However, even manual valves fail sometimes, so the "worst-case"
assumption presented for assessment purposes is still valid.
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Job A/LERESl/p.4
EPA-9 Comment noted. Violations of the standards for ozone and sulfure oxide standards in
Ohio were noted in paragraph 3.100. Ashtabula, Cuyahoga, Erie, Geauga, Lake, and
Lorain counties have been designated nonattainment for ozone; parts of Cuyahoga,
Erie, Lake, and Lorain counties are nonattainment for sulfur oxides. In addition,
Erie County, Pennsylvania, is designated nonattainment for suspended particulates.
Prior to construction of facilities that could add to ambient concentrations of
pollutants which are nonattainment, emission offsets may be required to meet State
Implementation Plans. An example is the treatment plants mentioned in paragraph
A.122. In such a case, the state new source permitting authority should be con-
tacted in regard to the need to apply for emission offsets.
EPA-10 Errata to paragraph 1.071 to be inserted after third sentence of the paragraph as
follows: "The Corps notifies the USEPA by public notice of those permit activities
requiring a Water Quality Certification. Where a discharge from one state may
affect the water quality of another state, the Administrator of USEPA must notify
the affected state. The state that may be affected by the proposed discharge then
has the opportunity to comment on the 401 certification".
EPA-11 Detailed analysis of ways to set up the regulatory Task Force through cooperation of
the federal and state govenments is outside the scope of this document, which is an
analysis of the environmental impacts of a proposed federal action. Questions as to
membership and procedures, although very important, are more properly debated else-
where. Additionally, see Topical Response Number 3 on the Task Force and Federal
Regulatory Authority.
EPA-12 At the current programmatic stage of development, there is no way to estimate the
amount of dredging or the pollution classification at the dredging site. However,
dredging in these areas is covered under the permit requirements of Section 10 of
the River and Harbor Act of 1899. Standard procedure used by the Buffalo District
Corps of Engineers for major dredging projects in these Lake Erie harbors includes
consultation with USEPA regional offices to determine the necessity for sediment
testing, the type of testing required, and the testing locations. On a site-
specific basis, thorough evaluation and interagency coordination would occur during
permit application review.
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Job A/LERESl/p.5
EPA-13 The intention of paragraph 1.069 was the'review of Corps permit applications by the
USEPA regional offices. We did not mean to imply that Headquarters would review the
applications. The section responsible for such reviews in the various regional
offices was at one time called the Office of Federal Activities.
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FAA-1 No response required.
Job B/LERESl/p.1
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SCSO-1 No response required.
Job C/LERESl/p.l
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Job D/LERESl/p.1
NRC-1 The statement concerning radiological health and safety impacts and the effects on
U.S. Nuclear Regulatory Commission (NRC) actions is acknowledged. Should U.S. Lake
Erie gas development ultimately be determined environmentally acceptable in princi-
ple, the next step would be the review of any specific proposals received from
operators. Operators would need Corps permits, and their applications would undergo
a public interest review. The Buffalo District will ensure that the NRC is notified
of any proposal related to gas development that is located within five miles of the
Perry Nuclear Power Plant.
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Job E/LERESl/p.l
HUD-1 The Buffalo District would ensure that appropriate U.S. Department of Housing and
Urban Development (HUD) offices are notified of specific gas development proposals
to determine the proximity to HUD projects and to afford the opportunity for comment
On a programmatic level, it would be difficult to project noise impacts in more
detail than contained in the DEIS.
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Job F/LERESl/p.1
FHWA-1 No response needed. We appreciate your'cooperation in our effort to recycle copies
of the document.
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Job G/LERESl/p.l
HHS-I Release and possible combustion or explosion of gas from a ruptured onland flowline
or from a gas treatment plant is an event with low probability but high potential
hazard. The effects of such an accident on human life and health would depend
greatly on location and time of occurrence, as well as other circumstances. The
risk of such an accident also exists for gas from onland wells, and is thus not
unique to this program. The consequences of an underwater flowline rupture would
likewise depend upon location, timing, and other circumstances.
HHS-2 The statement by Centers for Disease Control is correct; paragraph 1.100 and para-
graph D.041 should have added to them: "Local building codes and zoning should be
modified so placement of flowlines and gas facilities can be done not only to minimize
land use and water quality impacts and to be esthetic, but also to minimize loss of
life in case of accident such as the explosion discussed in paragraph 4.129."
The discussion of the risk anslysis and engineering considerations to implement that
placement is beyond the scope of this document. Presumably gas companies take these
precautions routinely.
HHS-3 The predominant direction of flow along the U.S. shoreline (central and eastern
basins) is northeastward, essentially parallel to the prevailing southwest winds and
parallel to the shoreline (paragraphs 3.032 and 3.045). The dominant winds and
currents further reduce the probablility of spills reaching riparian areas.
New York leasing requirements prohibit drilling within 0.5 mile of a potable water
intake. This requirement is recommended as a minimum for the entire development
area.
In addition, a nearshore buffer zone of 1 mile (1600 m) has been recommended. With
this zone, development activities would be sited lakeward of most potable water
intakes (Table 3.3), thereby providing for a reaction time to spills before riparian
interests are potentially impacted and also protecting fish spawning and nursery
areas (paragraph 3.043). Several intakes are beyond the nearshore buffer zone,
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Job G/LERESl/p.2
however, and development is restricted 'to a distance of at least 0.5 mile from any
potable water intake. Liquid hydrocarbon spills would be concentrated at the water
surface. Dispersion modeling (Appendix C) indicates that within 0.5 mile from the
point of release, other chemical inputs (except hydrogen sulfide) from accidents
(Table 4-5) or routine activities (Tables 4-3 and 4-4) would be within drinking
water standards. The larger water treatment facilities have the ability to remove
or reduce the concentration of potential contaminants associated with developmental
activities (Table 3-5). Finally, the possibility of intake exposure can be further
reduced by the permitting agency through site-specific EIS's.
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Job H/LERESl/p.l
DOI-1 Comment acknowledged. Should gas development in the U.S. Lake Erie be determined
environmentally acceptable in principle, the Buffalo District would continue to
coordinate with the U.S. Fish and Wildlife Service on an application-specific basis
The only potential for Corps regulatory involvement in onland development would be
operations that involved the discharge of dredged or fill material into waters of
the United States and their adjacent wetlands. We do not currently foresee any
regulatory involvement in upland development of oil and gas.
DOI-2 Statement concerning ownership and mineral leasing of federal land is noted. The
discussion in the DEIS of onland gas development was provided to give a comparison
of environmental impacts of onland vs. offshore development. There is no actual
onshore portion of the Reference Program outside of pipelines from shore to
processing and compressor stations and any facilities in harbors. Refer to Topical
Response Number 11 on the Onland Alternative Program, which provides a more detailed
account of our reason for analyzing an onland program. The road widths and pipeline
rights-of-way for the onland program were for the purpose of worst-case analyses.
The Corps and USEPA have no regulatory control over these onland activities; how-
ever, we do concur that the Bureau of Land Management stipulations and recommenda-
tions result in minimal effect while still allowing for development.
DOI-3 Comment noted. This comment should be taken into consideration by the Task Force
and/or appropriate permitting authorities. It should be noted, however, that air
quality impacts in populated areas will be small because the volume of waste is
small, and the rigs will be at least one mile from shore.
DOI-4 The Buffalo District will coordinate the cultural resources technical report with
the State Historic Preservation Offices (SHPOs) in the three states and with the
U.S. Department of the Interior. The Buffalo District will also consult with the
SHPOs in accordance with Corps regulations 33 CFR 320-329 on an application-specific
basis should gas development be determined environmentally acceptable in principle.
Considering the programmatic nature of this DEIS, with impacts being addressed on a
generic basis, consultation is best performed on specific applications when proposed
locations and methods of work can be correlated with potentially sensitive historic
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Job H/LERESl/p.2
and archeological sites. On a generic'level, the cultural resource impacts are
contained in the DEIS, Chapter Four. Chapter Three of the DEIS provides generic
cultural resource information relative to the existing environmental setting. In a
meeting held on 21 August 1978 in Washington, DC, between the Buffalo District Corps
of Engineers and the Interagency Archeological Services group of the Heritage Conser-
vation and Recreation Service (U.S. Department of the Interior), it was agreed that
the following mitigation measures be provided:
• Where bottom anomalies are encoutered, mitigation can be achieved by moving the
drilling rig or pipeline a short distance away from the site of this potential
resource. In such cases, the Heritage Conservation and Recreation Service (HCRS)
indicated that the applicant would not be required to investigate the anomaly any
further.
¦ Where the pipeline or drilling rig cannot be rerouted or moved, the applicant
will be required to identify the anomaly and determine its historic or archeo-
logical significance. Should the investigation indicate that it is significant,
certain prescribed procedures must be followed.
Where contact with archeologically sensitive areas is almost certain to occur,
the HCRS advised that they would request that gas drilling and all appurtenant
activities be prohibited.
The cultural resources report to be reviewed by the SHPOs and U.S. Department of the
Interior will suggest various procedures for locating sensitive areas, such as
remote sensing techniques, and various procedures for mitigation. The actual consul-
tation process, however, would be on an application-specific basis.
The types of procedures to be contained in the cultural resources report are basic-
ally the same as those already being used for Outer Continental Shelf exploration
activities.
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DOI-5 Copies of the DEIS were sent to the New York State Office of Parks and Recreation,
to the Secretary of Pennsylvania Department of Environmental Resources, and the
Director of Ohio Department of Natural Resources for review and comment. None of
these agencies advised that their comprehensive plans for recreation would be
adversely affected. The comments of these agencies relative to recreation are being
addressed in this Final EXS. On an application-specific basis, the Buffalo District
«
would coordinate with these agencies to ensure that specific proposals do not con-
flict with statewide comprehensive outdoor recreation plans. It is also assumed
that the leasing programs of the three states would include consideration of these
recreation plans.
DOI-6 Capsize of a drilling rig is considered to be an accident with low probability of
occurrence, and the probability of an oil blowout is considered to be very small
(see Table 1-35). The staff maintains that the effects of such accidents have been
adequately assessed at the programmatic level in Table 4-5 and the associated text.
D01-7 Although the possibility of accidents involving the release of crude liquid hydro-
carbons or diesel fuel is considered to be nearly zero, the potential environmental
consequences of such accidents are examined in Tables 1-35 and 4-5 and in Appen-
dix C. Indeed, a major release of liquid hydrocarbons has not been recorded during
the 68 years of natural gas development in Canadian waters.
It is beyond the scope of the programmatic DEIS to determine the state-of-the-art of
cleanup technique or the technical capacity of legally designated agencies. We have
assumed the capability of existing legislation to work. Agencies and procedures
relating to spills are outlined in the section on Accident Contingency Plans (para-
graphs 1.076-1.084).
Worst-case estimates of crude oil and/or diesel fuel releases are 300 bbl (Appen-
dix C) and 16,000 gal (Appendices B and C), respectively. Therefore, the amount to
be contained or cleaned up is at worst relatively small and in this context would
not require complex containment and cleanup techniques. A spill prevention control
and countermeasure plan (SPCC) must be: developed by owner/operators, certified by
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a registered engineer, and approved by appropriate agencies. Both the New York
leasing requirement (Table A.l, Item 50) and state/federal regulations (paragraph
1.084) provide for procedures, methods, equipment, and other requirements to prevent
the discharge of hazardous substances. See Topical Response Number 7 on Contingency
Plans and Cleanups.
DOI-8 See Topical Response Number 1 on the Canadian Experience in Lake Erie and Topical
Response Number 2 on the Impacts of Accidents: Consideration of Canadian Experi-
ence. The staff maintains that more specific information regarding probable impacts
on aquatic and terrestrial resources is beyond the scope of the programmatic DEIS.
Site-specific information and impact assessments would be covered in site-specific
EIS's for natural gas development in Lake Erie.
DOI-9 The Onland Alternative Program is a hypothetical program developed for comparative
purposes only. Impacts of the Onland Alternative Program are assessed in the DEIS.
See Topical Response Number 11 on the Onland Alternative Program.
D0I-10 The USEPA (Herdendorf 1980) reported that although the effectiveness of nutrient
controls in reversing eutrophication in Lake Erie cannot be demonstrated, the halting
of further degradation is an important first step. Also, many of the new treatment
facilities are just now being placed in operation. Modifications in agricultural
practices will reduce the loading of nutrients to the tributaries, but these changes
will not be reflected in water quality improvements for several years, due to slow
migration of sediment to the Lake. It is important that this start at improving the
conditions of Lake Erie be continued and that new methods of lake restoration be
explored.
DOI-11 See Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on the Impacts of Accidents: Consideration of Canadian Experience.
DOI-12 The Onland Alternative Program is developed for comparative purposes, and impacts of
and measures to control chronic and acute oil and salt water pollution from the
Onland Alternative Program are addressed to the extent necessary (Chapters 2 and 4)
at the programmatic DEIS level. See Topical Response Number 11 on the Onland Alter-
native Program.
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DOI-13 See Response DOI-9.
DOI-14 See Response D0I-10.
DOI-15 According to the U.S. Survey of Current Business, 1965 dollars may be converted to
1980 dollars by using a multiplication factor of 2.44. This produces a current
value of approximately SO million dollars. However, efforts to develop a salmonid
fishery and to stimulate the walleye fishery in the Lake in combination with the
general increase in fishing as a recreational pasttime have probably increased the
value of the sport fishery._ The actual value may be calculated by a number of
methods, depending on the specific information required. That the Lake supports a
valuable resource is not in question.
DOI-16 See Response DOI-15.
DOI-17 The staff acknowledges the error; however, the assessment is unchanged. Obviously,
commercial fisheries are important economic institutions in all the states bordering
the Lake. Fish are commercially sought not only for human consumption but also for
resale to use as bait in sport fishery. As is evidenced by the comments, the com-
mercial fishery is concerned about the proposed action and its effect on harvest and
gear. The comments also indicate conflicting statements relative to the success of
net deflectors on wellheads. The Referene Program has proposed net deflectors on
wellheads as mitigation (paragraph 4.208).
DOI-18 See Response DOI-17.
D0I-19 The statement in paragraph 3.079 that " ... Pennsylvania has no overall wetland
policy at present ... " may not be totally accurate. Amendments to the Dam Safety
and Encroachment Act (32 P.S. Sect. 693.1-693.2) and regulations implemented on
September 27, 1980 (25 PA Code CH 105), now provide comprehensive protection to
wetlands. The DEIS was essentially written prior to this date.
D0I-20 Information developed in Chapter Three on Environmental Setting should be used in
Chapter Four on Consequences. The staff maintains that impacts to raptors are minor
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and, therefore, were not included in Chapter Four. Documentation by recent infor-
mation, therefore, is not needed for assessment purposes.
DOI-21 The statement as presented is incorrect. Assessment statements in Chapter Four
(Consequences), however, are not altered by this mistake.
DOI-22 Comment noted.
DOI-23
The staff maintains that treatment of endangered species is adequate at the program-
matic DEIS level (paragraph 4.090). Impacts to endangered species would be highly
site-specific and treated in site-specific EIS's for natural gas development.
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FERC-1 In regard to coordination procedures, it is important to note that we relied on the
establishment of the technical team for this project in 1977, our notice of intent
to prepare the EIS as published in the Federal Register of 30 July 1979, and our
public notices announcing public hearings. Part of the difficulty in our early
coordination efforts to establish the technical team stemmed from the reorganization
of the federal energy agency structure during that period. Additionally, our notice
of intent to prepare the EIS failed to elicit any inquiries from federal agencies
not already on the technical team. We did advise, by public notice, the following
Federal Energy Regulatory Commission (FERC) offices of our pre-EIS public hearings:
License Projects Division of FERC, Washington, DC; FERC regional office in New York,
NY; and FERC regional office in Chicago, IL.
FERC-2 The short-term supply outlook as determined by FERC's Office of Pipeline and Producer
Regulation is noted. This outlook is supportive of the discussion given in para-
graph 4.184 of the DEIS, which advised that no shortages are predicted at this time.
FERC-3 The reasons provided in this comment for improved short-term supply outlook are
consistent with those given in paragraph 4.184 of the DEIS which included conserva-
tion, fuel switching, increased prices, and state incentives for increased local
production. Economic slow-down and competition from alternative fuels are acknow-
ledged as important factors additional to those in the DEIS. We concur with the
statement that until the effect on production of the Natural Gas Policy Act of 1978
(NGPA) can be better evaluated, the long-term outlook is currently uncertain and
that no realistic forecast of natural gas availability can be projected beyond the
next few years. See also Topical Response Number 12 on the Need for Natural Gas.
FERC-4 Although the DEIS does indicate the role of FERC in paragraphs 1.014 and 2.007, we
agree that a clearer delineation of the Commission's regulatory role in adminis-
tering the NGPA and its responsibilities in interstate natural gas regulation would
improve the overall report. We have adopted the wording suggested in the comment;
the suggested wording is included in the errata section of this Final EIS as new
paragraph 1.015a to be inserted between paragraphs 1.015 and 1.016 of the DEIS.
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FERC-5 The national need for all forms of enei'gy resource development is beyond the scope
and mandate of the DEIS. However, the need to develop all sources of potential
natural gas supply is discussed (see pp. 2-5 to 2-16). See also Topical Response
Number 12 on the Need for Natural Gas.
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SCSN-1 Comment noted.
Job J/LERESl/p.1
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DOC-1 Since gas development in Lake Erie will'require federal permits for various activi-
ties and structures, it is the responsibility of the federal agencies to determine
the consequences of permit issuance. The analysis of environmental impacts requires
that a program of some type be reviewed in terms of potential benefits and detri-
ments to the human environment. Since the DEIS was prepared without benefit of a
specific proposal, it was necessary to develop the Reference Program. Information
on the engineering design of the program, economics, and gas reserve estimates had
to be developed to determine if there were adequate technologies to limit the release
of materials to the Lake to an acceptable degree and to determine if the program
that results in the smallest releases to the environment would be economically
feasible. The DEIS was prepared in anticipation of future interest by operators in
U.S. Lake Erie gas development. Should development be found acceptable in principle
and should operators show an interest in developing the reserves, then at that point
in time, the private sector and the states would look closely at the potential
reserves and economic aspects. They would also propose the specific engineering
design that they intended to utilize. See Topical Response Number 10 on the Refer-
ence Program Concept.
DOC-2 Refer to Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on Impacts of Accidents: Consideration of Canadian Experience.
DOC-3 Chapter Two of the DEIS presents information on those alternatives to Lake Erie gas
development that are reasonable and viable alternatives to the proposed action. The
chapter presents information indicating that the most viable alternatives are those
which utilize existing technology on proven reserves, have sufficient infrastructure
for increased development, and are or will be tied into the Lake.Erie region markets
(see paragraph 2.044). Discussion of reasonable alternatives to a proposed action
is necessary to make a reasoned decision on the action and is mandated by the regula-
tions promulgated under the National Environmental Policy Act of 1969 (NEPA).
Economic viability of alternatives is a factor used in determining if an alternative
is reasonable. The chapter also advises of the environmental effects of gas to be
imported to the contiguous United States from development in Alaska and the Gulf of
Mexico.
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DOC-4 Chapter Three of the DEIS focuses on those environmental setting factors that will
either affect (e.g., geology, air quality) or be affected by any development in Lake
Erie. Energy use is part of the existing and projected setting of the region and is
a factor to be affected by any development. The environmental setting appropriately
includes socioeconomic factors. The existing setting is contained in Environmental
Impact Statements as mandated by regulations promulgated under NEPA. It is neces-
sary to determine ambient conditions of the human environment to determine how they
will affect or be affected by a proposed action. Development of the gas reserves by
the Corps or USEPA is not being considered. However, the three states have expressed
an interest in leasing the underwater land to operators. We are viewing the develop-
ment from our regulatory standpoint in the event that, after analyzing their respec-
tive needs, the states and potential operators determine to proceed with proposals
to develop.
DOC-5 Refer to Topical Response Number 11 on the Onland Alternative Program. We did
advise in paragraph 2.063 that it appears reasonable to assume that reserves of
natural gas onland will continue to be developed and that if accelerated exploration
and development were to occur upland, partial compensation for the absence of lake
drilling might be achieved under a scenario of severe gas curtailments.
DOC-6 There is no summary at the end of Chapter Four. The section cited in this comment
is entitled "Mitigation of Reference Program Consequences." The suggestions made
concerning the coloration and design of drilling rigs were to mitigate the esthetic
impact of the, program. Information in Appendix B was used to determine whether or
not a program as conservative as the Reference Program would be economically viable.
The Appendix also conveys information on the type of technology that would result in
the smallest release to the environment of materials used and residuals generated.
The purpose of the DEIS is not developmental but rather environmental and regulatory
in nature.
DOC-7 As indicated above, the study is not developmental. The Reference Program is being
used to assess potential environmental impacts of gas development. If the Reference
Program is ultimately determined to be environmentally acceptable, it would be used
as a point of reference or guideline of acceptability for review of future specific
proposals. The specific proposals by operators (i.e., developmental plans) would be
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analyzed to determine their impact on the environment. The Reference Program pro-
vides valuable information and guidelines for the review of specific proposals and
points out areas where more detailed study is needed at the time of permit appli-
cation reviews. See Topical Response Number 10 on the Reference Program Concept.
The DEIS essentially presents the worst-case type of analysis. Total development is
assumed for several reasons. First, the total development assumption provides
worst-case environmental impacts and gives an indication of the possible cumulative
effects on a worst-case basis. The other reason for assuming accelerated develop-
ment was for the purpose of economic feasibility analysis. The economic evaluation
attempted to simulate development over a period of years, with the productive life
of individual wells being 15 to 20 years. The program was initiated in 1980 and
accelerated to maximize the use of cost data based on known trends (see paragraph
1.152). The DEIS modeling cannot predict the degree of interest that operators may
show, the competitive aspects of development, or future reactions and schemes for
development by operators and states.
DOC-8 The DEIS advises of the necessity for the Reference Program at this point in time in
paragraphs 1.005, 1.006, 1.007, 1.020, and 1.021. If the Reference Program were
deleted from the report, there would not be any proposal to analyze since no pro-
posals have been submitted by operators. The Reference Program is the crux of the
impact analyses, the protective technologies and methodologies, and the guidelines
of Appendix D. See Topical Response Number 10 on the Reference Program Concept.
DOC-9 Refer to Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on Impacts of Accidents: Consideration of Canadian Experience.
DOC-10 Paragraph S.018 is a summary of the more detailed information in the text. The
analysis itself is contained in Chapter One (section on hazards and accidents),
Chapter Four (sections on water quality, water supply, and aquatic ecology impacts),
and in Appendix C (worst-case accidents).
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DOC-11 See Response DOC-10.
D0C-12 Refer to Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on the Impacts of Accidents. Consideration of Canadian Experience.
D0C-13 Paragraph S.026 is a summary of the more detailed information in the text. The
analysis is contained in Chapter Four (sections on water quality, water supply, and
aquatic ecology impacts). Bioaccumulation was given in the DEIS as a potential
impact (paragraph 4.046).
D0C-14a Refer to Topical Response Number 11 on the Onland Alternative Program. Also, the
results of our comparative analysis of offshore vs. onland impacts as contained in
Chapters Two and Four of the DEIS do not support the conclusion in this comment that
onland development is potentially less harmful to the environment. The DEIS did not
make any statement that onland development in the region does not exist. The ongoing
operation is described in paragraphs 2.014 to 2.016.
DOC-14b We are unable to provide a response to the question about ending projections at the
waters edge since we cannot determine which figures are being questioned or whether
they are numerical figures or graphic figures, and we have no indication of which
projections are being questioned. However, most of the information in Chapter One
is applicable to the Reference Program which is an offshore program, and the off-
shore area ends at the waters edge.
D0C-15 Refer to Topical Response Number 1 on the Canadian Experience.
DOC-16 See Response DOC-7 concerning the reason for assuming accelerated development.
Also, economic and environmental impact modeling cannot predict future political and
social factors that may affect energy demand.
D0C-17
Refer to Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on Impacts of Accidents: Consideration of Canadian Experience.
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DOC-18 The western basin is outside of the area of the proposed action; however for addi-
tional information on anoxic bottom waters see Britt (1955), Britt et al. (1968),
and Zapotosky and Herdendorf (1980).
DOC-19 See Response DOC-3.
DOC-20 The phrase used in paragraph 4.002 concerning the fact that the Corps and USEPA may
require certain information was intended to convey two concepts. First, the phrase
means that the agencies have the authority to require specific information on a
proposal. Secondly, the word "may" was used because of the generic nature of the
DEIS and to express the fact that data needs will vary from proposal to proposal and
from site to site. Conceptual design does not negate future data needs.
DOC-21 Under certain circumstances during the drilling of the primary surface hole with a
drillship, the cuttings are not collected for onshore disposal; therefore, there
will be a greater impact from onland disposal in the Onland Alternative Program.
DOC-22 See Topical Response Number 6 on Sediment Resuspension and paragraph 4.046 where
potential for bioaccumulation is discussed.
DOC-23 See Response HHS-3.
DOC-24 Although the benthic community may not be in intimate contact with the entire sub-
strate profile that could be disturbed, the community is in contact with upper
layers of the profile which tend to have the higher heavy metal concentrations (see
Table E.6). The impact assessment for paragraph 4.034, therefore, remains unchanged.
DOC-25 The conclusions are consistent, although some clarification is needed. The cited
paragraph 4.059 on recreation advises of water quality impacts. The statement most
likely refers to the temporary impacts on water quality during nearshore construc-
tion (pipeline burial, landfall work) and not the drilling activities which are
located outside the one-mile buffer zone. In Table 4-3, it is indicated that pipe-
line laying and burial will have a minor impact on water quality.
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DOE-1 The need for natural gas in the Lake Erie region was discussed in several sections
of the DEIS (see paragraphs 1.009, 1.018, 3.130-3.136, and 4.180-4.187). See also
Topical Response Number 12 on the Need for Natural Gas.
DOE-2 See Topical Response Number 12 on the Need for Natural Gas.
DOE-3 The importance of natural gas to the regional economy and to industry in the
Lake Erie region is discussed in several sections of the DEIS (paragraphs 1.009,
1.017, 1.018, 3.125-1.137, 4.185, and 4.201).
DOE-4 The south shore of Lake Erie is well served with a number of natural gas pipelines.
For example, in New York paralleling the Lake (onshore—several miles from the
Lake), the Tennessee Gas Pipeline Company owns a 26-inch pipeline; in Pennsylvania,
several lines owned by the Pennsylvania Gas Company (10- and 12-inch) are close to
the shoreline; and in Ohio, a number of pipelines (a 20-inch line, and numerous
smaller pipelines) owned by The East Ohio Gas Company and Columbia Gas of Ohio,
Inc., serve the nearshore area. Apparently, any excess natural gas supply could be
moved through the existing pipeline network to service the New England market.
DOE-5 Comment noted.
DOE-6 Comment noted.
DOE-7 Comment noted.
DOE-8 Comment noted.
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DOS-1 la the Reference Program, it was assumed that no drilling would take place within
0.5 mile of a potable water intake.
Detailed analysis of the vulnerability of specific water intakes to adverse impacts
as a result of drilling activities must await preparation of site-specific environ-
mental impact statements. The conservative assessment contained in the programmatic
DEIS indicates little cause for concern over impact to potable water supplies with a
0.5-mile buffer zone.
Most gas reservoirs encountered in Lake Erie are expected to produce dry gas, i.e.,
gas with very little associated condensate. Although any liquid hydrocarbons encoun-
tered would probably not flow to the surface without pumping because of the low
pressures found in the target formations, the Reference Program assumes that, during
the initial formation test, a well found capable of significant production of natural
gas liquids (5 gallons per day is the assumed cutoff level) would be plugged and
abandoned (paragraphs 1.038-1.039).
See Topical Response Number 8 on Glycol Chlorination and Topical Response Number 9
on Water Supplies and Treatment Costs.
DOS-2 Refer to Topical Response Number 5 on the Great Lakes Water Quality Agreement of
1978; the 1909 Boundary Waters Treaty between the U.S. and Canada; and the Inter-
national Joint Commission.
DOS-3 The Reference Program is designed to conform with U.S. standards, rules, and regu-
lations and occurs wholly within U.S. waters. Thus, calcium chloride and polybrine,
when used for operations in U.S. waters, shall not be discharged into U.S. waters
under the Reference Program. Likewise, the disposal of the material in the United
States must conform to waste management strategy.
In the Reference Program, drilling is assumed to occur no closer than 0.5 mile to
the U.S.-Canada boundary. A modeling analysis of water quality effects of routine
and accidental discharges from well sites has shown that for conditions prevailing
in Lake Erie, a small release of material 0.5 mile from the international boundary
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could result in a small elevation in the concentration of the spilled material at
the boundary. Such effects would be localized, temporary, and small in magnitude.
Concentrations are expected to meet U.S. drinking water standards and water quality
criteria for freshwater aquatic life. No detectable effects are expected near the
Canadian shoreline.
In the event of a loss of well control or a gas pipeline break, the concentration of
hydrogen sulfide close to the source may be high and could, under unfavorable condi-
tions, exceed water quality criteria for freshwater aquatic life (Table 4-5). Such
occurrences would be infrequent, localized, and temporary, and are expected to have
no significant effect on populations of biota in U.S. or Canadian waters. No effects
are expected near the Canadian shoreline.
DOS-4 Executive Order 12114 requires that all federal agencies, encompassed by and not
excluded from the order, taking major federal actions outside the United States must
have in effect procedures implementing the order. Corps procedures for implementing
the order are contained in paragraph 25(b)(3) of 33 CFR 230 (Corps regulations for
implementing the National Environmental Policy Act) and general policy guidance for
all Department of Defense components is contained in 32 CFR part 197. In considera-
tion of these cited implementation procedures and the results of the programmatic
DEIS, the following factors have led to the conclusion that an environmental review
document in accordance with E.O. 12114 is not required: First, the Reference Program
constitutes an activity that takes place wholly within the United States, including
a 0.5-mile buffer zone from the international boundary, and does not constitute a
major federal action outside of the United States. Secondly, based on the analysis
of impacts as contained in the DEIS and this Final EIS, the Reference Program is not
expected to do significant harm to the environment of places outside the United
States as defined in 32 CFR part 197. Finally, the Reference Program is not expected
to have any significant effect on waters or air outside of the United States nor
will it provide to another nation a product--or involve a physical project which
produces a principal product, emission, or effluent—that is strictly prohibited or
strictly regulated by federal law in the United States because its toxic effects on
the environment create a serious public health risk.
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DOS-5 The Reference Program has established a one-mile buffer zoae to reduce the potential
for any releases to affect the inshore zone. Dispersion modeling indicated that
concentrations of accidental releases would be extremely low (see Appendix C and
Table 4-5) and that impacts would be minimal. See Response DOS-3.
DOS-6 Refer to Topical Response Number 6 on Sediment Resuspension. Impacts to water
quality are presented in Tables 4-3 to 4-5.
DOS-7 The composition of completion fluids is described in paragraph 1.107 and in Table 1-30
These fluids would not contain hydrochloric acid. The frequency of release will
vary by geographical area and in time, and may be estimated from Table 1-31. Any
releases during well decommissioning would occur approximately 15 to 20 years after
drilling (paragraph 1.101). Impacts to water quality are presented in Tables 4-3
to 4-5.
D0S-8 Representative components of completion fluid are identified in Table 1-30. Com-
ponents are relatively nontoxic and/or present in relatively low concentrations,
especially after minimal dispersion in Lake Erie. Impacts to plankton populations
would be temporary and local. Impacts to water quality are presented in Tables 4-3
to 4-5.
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CG-1 No response required.
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PFC-1 Comment noted.
PFC-2 See Response DOI-15.
PFC-3 See Response DOI-17.
PFC-4 This refers to the Canadian program (not the program assumptions in the DEIS), which
specifies that the wellheads will either be placed in caissons or have deflectors
over the top of them if they stick up off the lakebed. See also Response DOI-17.
PFC-5 See Response DOI-17.
PFC-6 See Topical Response Number 6 on Sediment Resuspension.
PFC-7 It is possible that a pipeline could be snagged by a gill-net anchor. However, the
lines are made of steel and designed to withstand the high pressures of producing
wells. This will reduce the possibility of a rupture occurring. Additionally,
up-to-date pipeline maps will be provided for the reference of all commercial
fishermen.
It should be noted that the impacts of accidents of this type are covered in the
DEIS.
PFC-8 See Response DOI-17.
PFC-9 Comment concerning onland development is noted. Onland development activities as
indicated in this comment are beyond the regulatory control of the Corps of Engi-
neers and comparisons of those programs to ones subject to the Corps regulatory
permit program would not be appropriate. In regard to violations of Corps permits,
the District Engineer has the authority to modify, suspend, or revoke permits if he
determines that the public interest requires these actions. The in-lake program
would also be subject to Corps monitoring and enforcement actions. Considering the
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low number of drilling rigs that are estimated in the Reference Program (eight
drilling rigs) and the fact that Corps permits would require information on loca-
tions of structures and rigs, the in-lake program would appear to be more easily
monitored than an onland program which is scattered throughout the region. Addi-
tionally, the in-lake program would be subject to the various accident contingency
plans listed in paragraphs 1.076 to 1.084 of the DEIS. See also Topical Response
Number 10 on the Onland Alternative Program.
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NYAM-1 The belief cited in this comment that the DEIS does not recognize the importance of
prime and unique farmlands is incorrect. Paragraphs 3.093, 3.094, A.092, 4.093, and
4.105 indicate the importance of prime and unique farmlands and the impacts on these
farmlands. The impact analysis, however, is constrained by the lack of specific
sites for various onland activities and the lack of specific proposals. Proposal-
specific information .would be needed to determine if gas processing and compressor
station atmospheric emissions would have any effect on prime and unique farmlands.
However, Prevention of Significant Air Quality Deterioration permit requirements
would include consideration of the impacts on vegetation and soils. A specific site
is also needed to determine if these facilities and associated pipelines would be
located on land classified as prime or unique. Both the Corps and the USEPA are
cognizant of the Council on Environmental Quality (CEQ) memoranda and CEQ regula-
tions for preparation of EIS's in regard to prime and unique farmland impact
analyses and have followed required procedures. Specific agency policies for imple-
mentation of the prime and unique farmland analyses were also utilized in preparation
of this EIS. In this regard, the U.S. Soil Conservation Service is the federal
agency responsible for classification and inventories of prime and unique farmlands.
Prior to writing the DEIS, the Corps contacted all of the soil conservation offices
with responsibilities in the Reference Program area. We attempted to obtain county-
wide acreages of prime and unique farmlands and countywide maps showing the location
of these farmlands. The following were contacted: State Conservationist's Office,
New York State (Syracuse, NY), Soil Conservation Offices in Erie and Chautauqua Co.,
NY; State Conservationists' Office, State of Ohio (Columbus, OH); and the District
and County Soil Conservation Offices responsible for the following Ohio counties:
Lorain, Ashtabula, Ottawa, Sandusky, Cuyahoga, Erie, and Lake. We already had a map
of Erie Co., PA, which was prepared to demonstrate prime and unique farmlands.
However, as indicated in the DEIS (paragraph 3.094), all of the inventories and
countywide maps of prime and unique farmlands are not yet complete. Also, we would
be able to determine prime and unique farmlands to be affected if we had a specific
site and if the soil survey for that site and the listing of unique farmland on that
site were available. Although countywide listings are not always available, many
areas in various counties have been inventoried. The Corps of Engineers, Buffalo
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District, has copies of all the soils s'urveys that have beem completed in counties
along the Lake. When a specific site is known, we contact the Soil Conservation
Service and request a list of those soils that constitute prime farmland. Concur-
rently, we request delineation of any unique farmland on that particular site.
However, this DEIS is programmatic and there are no specific sites that can be
reviewed. Likewise, we do not have countywide inventories for the entire Reference
Program area. The DEIS was reviewed by the Soil Conservation Service and their
review does not indicate that we have neglected our responsibilities concerning
prime and unique farmlands [see comments received from the New York (DEC) and Ohio
(DNR) state conservationists].
The comment concerning state policy to preserve prime and unique farmlands relates
to a statement made in the DEIS concerning Pennsylvania. It was stated in the DEIS
that there has been a great loss of prime farmland as a result of urbanization.
Pennsylvania was given as an example in that Pennsylvania has recognized the impor-
tance of the loss and the need for a policy on farmland. Our use of Pennsylvania as
an example should not be interpreted to mean that other states have not recognized
the importance of prime and unique farmlands or that there is no federal policy.
NYAM-2 Comment noted. See Response NYAM-1.
NYAM-3 Comment noted. See Response NYAM-1.
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DEC-1 See Response CSS-8 and Topical Response Number I on the Canadian Experience.
DEC-2 Because of differences between the Canadian and U.S. regulatory frameworks and
differences between the Reference Program and the Canadian drilling program, a
detailed description in the DEIS of the Canadian experience with drilling for natural
gas in Lake Erie is considered inappropriate. The authors of the DEIS familiarized
themselves with the Canadian program and, in order to fill data needs, conducted a
field study in the vicinity of an operating drilling rig and a reconnaissance survey
of hydrocarbons in Lake Erie that included areas in which gas resources are being
developed. Results of these studies may be found in the following reports, which
are available from the National Technical Information Service or from the authors:
Ferrante et al. (1980) and Zapotosky and White (1980).
Additionally, see Topical Response Number 1 on the Canadian Experience, Topical
Response Number 2 on Impacts of Accidents: Consideration of Canadian Experience,
Topical Response Number 8 on Glycol Chlorination, and Topical Response Number 9 on
Water Supplies and Treatment Costs.
DEC-3 Refer to Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on Impacts of Accidents: Consideration of the Canadian.Experience.
DEC-4 Although the operational procedures in the Reference Program are assumed (see Topical
Response Number 10 on the Reference Program Concept), they nevertheless are very
realistic, feasible, and protective technologies currently in worldwide use. The
restrictions and guidelines of the program are similarly realistic, feasible, and
protective and are based on the results of the impact analyses in'the Draft EIS,
recommendations by the International Joint Commission, and various existing regula-
tions such as those pursuant to the Clean Water Act, Resource Conservation and
Recovery Act (RCRA), etc. If the Reference Program is ultimately judged to be
environmentally acceptable in principle, it would be used as a guideline or
reference point whereby future specific programs proposed by operators could be
weighed and balanced against it. As indicated in the footnote at the bottom of
page 1-7 (DEIS), future program proposals that vary significantly from the Reference
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Program and constitute relaxed technological performance standards could be evalu-
ated on a case-by-case basis to determine the consequence of allowing increasing
amounts of materials to be released to the environment. Undoubtedly, refinement and
evolution of the protective guidelines and technologies will occur as new informa-
tion is generated during proposal- and site-specific analyses and as studies are
performed relative to various acts and regulations—such as RCRA, the Safe Drinking
Water Act, Clean Water Act, and others. Although it is the states that have
authority over development and leasing of underwater lands in Lake Erie, the federal
government also has its responsibilities for activities related to gas development
(see Topical Response Number 3 on the Task Force and Federal Regulatory Authority).
DEC-5 Refer to the Topical Responses 3 and 4 on the Task Force and the Offshore Program
Office. Also, procedures for federal leasing and development of Outer Continental
Shelf (OCS) lands constitute a situation entirely different from the U.S. Lake Erie
program from both an administrative and regulatory standpoint. In the OCS, the U.S.
Department of the Interior, Bureau of Land Management (BLM), is the lead federal
agency with authority to lease lands. In regard to OCS development, where islands
or structures are to be constructed on lands that are under mineral lease from BLM,
that agency, in cooperation with other agencies, fully evaluates the potential
effects of leasing on the total environment. In these cases, the Department of the
Army permit review and decision is limited to the evaluation of impacts of the
proposed work on navigation and national security [33 CFR 322.5(f)]. In the case of
Lake Erie, the land is owned by the states and BLM is not responsible for leasing.
In this situation, on the federal level, the Corps is the lead federal agency, with
USEPA acting as a cooperating agency in the evaluation of impacts of development on
the total environment. The suggestions made in the DEIS concerning program adminis-
tration are those that we believe will shorten the time period for permit and lease
evaluations and reviews.
DEC-6 Comment noted.
DEC-7 The rationale for selecting few operators is presented in the DEIS (paragraph 1.088).
It is assumed that strict operational rules and regulations imposed by the states
(summarized in Appendix D) and relatively large capital requirements compared to
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onshore development of similar gas resources would limit the number of potential
operators willing to mobilize risk capital in the study region.
Competition among operators is noted in paragraph 1.087, but prediction of competi-
tive aspects is beyond the scope of this analysis.
Dry holes are assumed in the Reference Program (paragraph 1.090).
Profits and revenues presented in the DEIS are estimates based on the Reference
Program.
Refer to paragraph 1.036 of the DEIS. The economic evaluation is based on scenario
assumptions—well documented in the DEIS—regarding gas production, cost, price of
natural gas, etc. Any change in these variables would change the economic result.
Additionally, see Response DOC-7.
DEC-8 The staff believes that, during Reference Program activities, the mile-wide buffer
zone offers more protection to the valuable resources of Lake Erie within the
30-foot contour. Most of the recent studies in Lake Erie concerning the effects of
intake and discharge structures on adult and young fish and ichthyoplankton have led
to the general consensus that the protection of fisheries is best achieved if depths
on the order of 25 to 30 feet or greater are utilized. The 0.5-mile buffer zone
would allow Reference Program activities in less than 20 feet of water. The one-
mile buffer results in less esthetic impact and less interference with recreational
activities.
DEC-9 A 0.5-mile buffer exists only on the U.S. side of the international border with
Canada. The buffer-zone concept was developed to provide state and international
buffer zones so that drilling activities in one state or nation would not interfere
with natural gas reservoirs in close proximity across state or national boundaries.
The size of the buffer zone is based on the concept of one well per 640 acres.
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DEC-10 The choice of resource use is a state decision. Should the states determine that
gas development is a higher priority than sand and gravel areas they have a right to
deny state authorization for commercial extraction of sand and gravel. In that
event, Corps permits would not be issued where the state has denied its permits.
However, based on our analysis, we do not believe that concurrent development of
both resources in the same area is safe. The types of equipment used in dredging
operations could damage wellheads and pipelines.
DEC-11 To be supplied.
DEC-12 See Topical Response Number 10 on the Reference Program Concept and Response D0C-7.
DEC-13 See Response CSS-8.
DEC-14 As noted in Table 1-25, the cuttings are not contained and are released to the lake
water during drilling of the (primary) surface hole by a floating rig because of the
lack of "leverage" during this phase of drilling. Note that from the start of the
drilling, a jack-up rig is anchored to the lake bottom by its supporting legs. The
drilling of the secondary surface hole is the earliest phase of drilling that can be
done closed-cycle by a floating rig.
The rationale for the procedures in the Reference Program is given in para-
graphs 1.020 and 1.021.
DEC-15 Refer to Topical Response Number 1 on the Canadian Experience. The examination of
issues report (McGregor et al. 1978) explained the Canadian program. The DEIS
advised of certain Canadian strategies in the waste management section of Chapter One.
DEC-16 Comment noted. The Outer Continental Shelf study is probably being performed on
muds used in the marine program, not necessarily the type that would be used in Lake
Erie, and potable water supplies is not a concern in these marine environment studies.
DEC-17
Refer to Response CSS-8 regarding waste classification. Be advised of the difference
between RCRA determinations of hazardous vs. the discharge of materials to waterways.
The Clean Water Act, not RCRA, applies to these discharges.
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DEC-18 The commenter is correct. The Lockport Reefs were misidentified as structural traps
in paragraphs S.007 and 1.046 and in Table 1-2. They are indeed localized strati-
graphic traps.
DEC-19 Refer to Topical Response Number 3 on the Task Force and Federal Regulatory Authority
and Topical Response Number 4 on the Offshore Program Office. Some of the informa-
tional needs for a State Pollutant Discharge Elimination System permit parallel the
information needs of other permit application forms and there is inherent duplica-
tion in existing procedures.
DEC-20 Such constraints already exist (e.g., see paragraph D.002) in the form of various
permits required to construct or dredge. In paragraph S.016, it is concluded that
even with construction redistributing toxic sediment, impacts will be localized and
temporary. Also, on a site-specific basis, testing of sediment could be required to
determine toxic content and availability to organisms during resuspension, e.g., bulk
analysis of sediment, bioassays, bioaccumulation tests (if necessary), and elutriate
tests. After determining necessary and practicable steps to minimize impacts during
permit review, the Corps can condition permits for proper construction methodology.
Also, see paragraph 4.031 of the DEIS concerning silt screens.
DEC-21 The stimulation techniques and volumes of additives have been well-established and
documented as to their success in the Canadian drilling program, and similar methods
have been used at gas fields throughout the United States and the world. The well,
stimulation process requires much less fluid volume than does solution mining and is
employed over a shorter time period. The stimulation process, equipment, and
material requirements are discussed and listed in paragraphs 1.097 and 1.098 and in
Table B.4 of the DEIS.
DEC-22 This may indeed be true; however, the values and ranges indicated were derived from
reviews of numerous data on these parameters and form the basis for Reference Program
production and impact analysis scenarios. As such, they are only meant or need to
be approximations that are assumed in order to support programmatic effects of a
potential development program as hypothesized. It should be noted that the values
questioned include composites from both the Medina and Clinton, not only from the
Medina.
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DEC-23 The figures that are suggested for burial of pipelines serve as reasonable guide-
lines and are based on past permit application for various types of pipeline struc-
tures , such as water intakes and discharges for power plants and industrial facili-
ties. The site-specific studies (engineering) have generally shown that 5 to
10 feet of burial out to the 30-foot contour provides protection from ice. This
will not always be the case and must be refined based on site-specific considera-
tions and information on the structural aspects of the pipeline materials.
Response on anchoring to be provided.
DEC-24 The statement in paragraph 1.127 of the DEIS concerning the Canadian brine lagoons
indicated that the material is being held pending decisions on use versus disposal.
In the Reference Program, the abjective is to treat the material for removal of
solids, oil, and gas (paragraph 1.128). Paragraphs 1.110 and 1.119 provide informa-
tion on the potential makeup of formation waters and reasons why discharge to water-,
ways is not being considered.
DEC-25 The constraints are based on current engineering design and Canadian experience in
Lake Erie. Based on current engineering design and experience, these are realistic
guidelines for protection of water quality (that could result from rig capsize) and
protection of workers and the general public from accidents. On a case-by-case
basis, proposals would be compared to guidelines, and operators would be allowed to
demonstrate that their rig is suitable for the area (see paragraph D.038 of the
DEIS).
DEC-26 Orientation of these general shoreline type areas in Figure 1-13 to various towns
along the Lake is possible by comparison of Figure 1-13 landfalls to the landfall
areas shown on the large foldout map, Figure 1-1. The foldout is of larger scale
and shows the locations of certain towns and cities more easily than could be demon-
strated in Figure 1-13.
DEC-27 Reference to Article VII is made in Table 1-10 and is implied in paragraph 1.073.
The discussion on page 1-37, as cited in the comment, is directed at subject matter
such as mineral rights, leasing, the task force, and the offshore office.
Article VII does not pertain to the subjects included on page 1-37.
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DEC-28 All items in the miscellaneous category'refer to footnote "c", which indicated that
no standard currently exists. The requirement that pipelines, landfalls, and other
facilities be constructed to withstand the ice and wind damage from the 100-year
storm is listed in Table 1-10.
DEC-29 The production rate from a well from Lockport reef reservoirs and the cost associ-
ated with the development are documented in the DEIS. In the programmatic develop-
ment program of U.S. Lake Erie gas, no assumption was made of any Lockport reef well
in New York or Pennsylvania. These wells are assumed to be developed only in Ohio
(Lease Areas XXII and XIV). If Lockport reefs are encountered in New York or Penn-
sylvania, the cost described for Lease Areas XIII and XIV can be applied and bene-
fits can be calculated.
DEC-30 Statement of position noted.
DEC-31 The reasons for removal, environmental effects, and fluid releases are addressed in
paragraphs 4.037-4.049. Comment on current policy for onland development is noted.
DEC-32 To be provided.
DEC-33 To be provided.
DEC-34 To be provided.
DEC-35 New York State's current procedure of waste identification is consistent with the
Reference Program guideline (see paragraph D.025).
DEC-36 To be provided.
DEC-37 Comment acknowledged. A footnote will be included as an errata which indicates
that, in some instances, it would not be possible to avoid all areas listed in the
locational constraint column and that, on a site-specific basis, the placement of
structures in these areas would be analyzed to determine the significance of the
effect and to ensure that proper mitigation is implemented. The review would include
the opportunity for public comment.
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DEC-38 A summary map of the Reference Program w'as provided in the DEIS (Figure 1-1). A map
of pipelines which serve the area has not been included. The Argonne staff has
reviewed detailed pipeline maps of the Reference Program area. In general, the Lake
Erie region has a dense network of natural gas pipelines. The general direction of
natural gas flow is towards the east, northeast.
DEC-39 See Response DOI-7 and Topical Response Number 7 on Contingency Plans and Cleanups.
DEC-40 Examining the industry practice for financial evaluation, it appears that a 10%
discount rate was very commonly used. As a result, in the current study, a 10%
rather than 15% discount rate was used. Discount rate reflects cost of capital (and
risk of investment, etc.) which in turn reflects the expected rate of inflation. A
higher expected inflation may necessitate use of a higher discount rate. But, this
expectation would also require the use of a higher rate of cost and price escala-
tion. Both sides of the equation (cost and benefit) will rise. As a consequence,
one would not expect any substantial change in the results reported in the DEIS.
DEC-41 The staff agrees that this would have been a better approach for the analysis. But,
due to a lack of reliable data on probability distribution of production, this
approach was not followed. The staff did estimate the revenue and, hence, net
present value (NPV) and return on investment (ROI) with respect to various gas
production levels.
DEC-42 The economic results of the Reference Program represents one of many scenarios for
profitable, environmentally safe exploitation of Lake Erie's national gas resources.
It is based on specific drilling success ratios, rate of gas production, cost esti-
mates, and gas price increases. If these assumptions are altered, the results would
be different than those reported in DEIS. The rate of return on investment (ROI) as
reported in different studies are not very different than those reported in the DEIS
if the analyses were done on an after-tax basis. Only 20% of the lease areas have a
ROI near the high end of the range (see Table 1-36).
DEC-43 The conclusions reached in the DEIS comparison of upland and offshore impacts would
not change as a result of the update.
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DEC-44 The staff does not understand the comment. If this comment pertains to the use of
coke oven gas (COG) and geopressurized aquifers, then the aquifers have been
addressed and coke oven gas use poses the same results as those discussed for coal
gasification.
DEC-45 Depending upon the location of significant natural gas production in the 23-county
alternative study region, main transmission pipelines may be necessary. However,
according to FERC, and with reference to gas pipeline maps, this region is well
served with a dense network of gas transmission pipelines.
Also, the construction of thousands of miles of gathering systems and trunk lines is
assumed for the Onland Alternative Program (see paragraph 4.012).
DEC-46 Impacts associated with pipeline construction, operation, maintenance, and decom-
missioning are discussed in Chapter Four, erosion control measures are considered,
and pipeline removal is assumed for worst-case conditions.
DEC-47 Table 2-6 is presented for comparative purposes (Reference Program vs. Onland
Alternative Program). The statement that magnitude and frequency of terrestrial
impacts from the onland alternative is an order of magnitude greater than lake
drilling is derived from Chapter Four assessments at the programmatic level. Back-
ground information for impacts to aquifers (Table 2-6) is presented in Chapter Four
(groundwater hydrology, paragraphs 4.004-4.016).
DEC-48 Table 2-6 and paragraph 2.095 are presented for comparative purposes (Reference
Program vs. Onland Alternative Program). Appropriate detailed discussions are
provided in Chapters Three and Four (paragraphs 3.090-3.097 and 4.091-4.108).
DEC-49 See Errata for paragraph 3.052.
DEC-50 Paragraph 3.090 is a generalized discussion of major land-use categories such as
cropland, pasture, and urban. Although more recent information may exist, it would
not change the content of the paragraph since no new major land uses have been added
to the coastal zone, no significant shifts in general distribution have occurred,
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Job P/LERESl/p.10
and the use in acreages was not quantified. Both of the agencies cited in the
comment have responded to the DEIS and have not indicated that the generalized
information in this paragraph is incorrect.
DEC-51 See Errata for Table 3-9.
DEC-52 A revision of population projections in the DEIS is not necessary because Reference
Program impacts would remain unchanged.
DEC-53 The information in the tables were projections at the time they were made by McGraw-
Hill in 1978. They were not actual reported data (see footnote "a" to Table 3-13).
DEC-54 The onland pipeline right-of-way given in the DEIS was provided as worst-case. This
was done to be consistent with the rest of the report which bases all analyses on
the worst case.
DEC-55 The area generally contains prime and unique.farmlands. The grape growers in the
area may have some small wells and pipelines, but they may feel differently if a
processing plant is proposed. The cited paragraph, 4.093, pertains to production
facilities.
DEC-56 Although we agree that there should be noise guidelines, neither the Corps nor the
USEPA could enforce such guidelines and, as such, it would be more appropriate to
include noise guidelines in either the state program or through local government
ordinances. Paragraph 4.097 advises of these means to implement noise guidelines.
DEC-57 The volumes (in acre-feet) of wastes produced by the Reference Program are presented
in Table 1-31. The number of waste disposal sites will be contingent upon the depth
and area (i.e., the volume) of the average site (see also Response EPA-4).
DEC-58 As mentioned in paragraph 4.145, the esthetic impact of soil exposure relates to the
actual construction periods, and the scars will heal with proper revegetation. Soil
exposure, no matter what the time limit of existence, is still a significant visual
Impact.
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DEC-59 It was not assumed that the propensity to consume was 0.5. A multiplier of 2.0 for
direct and indirect employment has not been verified (Table 4-21); it was assumed
after examining multipliers in a number of counties. When one takes into account
(1) wide variance in multipliers reported from different projects in different
counties and industries, (2) the fact that the time frame is arbitrary for this DEIS
action, (3) the unknown state of the national and local economy, etc., it seems
reasonable to use one number as an approximation based on several such multipliers
reported in a variety of studies. A multiplier of 2.0 was chosen in this way.
Having indicated the source of the multiplier as poor, note that if either 1.0 or
3.0 had been used rather than 2.0, it would not affect the conclusion. Instead of
1842 induced employment in an area of about 4 million people (Table 3-10), we would
have about 921 (if 1.0 were used) or 2763 (if 3.0 were used). Clearly, induced
employment over a wide range of assumptions will not have a large impact in the area
of consideration.
DEC-60 It is generally accepted that man-made disturbances of natural slopes promote local-
ized increases in erosion rates. Thus, the statement in the DEIS is a valid one.
Secondly, the Reference Program as defined (pages 1-7 through 1-113) includes the
removal of pipelines as part of decommissioning. This is necessary in order to
render the analyses of potential impacts representative of worst-case conditions
that are anticipated to accompany gas development according to the Reference Program.
It should be noted that the Reference Program, although intended to be realistic, is
hypothetical. It is recognized that this development scenario may not be the case
in actuality, but nonetheless must be considered in terms of identifying the range
of impacts to be analyzed in order to fulfill the purpose of the programmatic DEIS.
See Topical Response Number 10 on the Reference Program Concept.
DEC-61 We agree that it may not always be possible to construct during seasons of low lake
level or low rainfall, but we would consider it as mitigation when possible. Con-
struction methodologies to mitigate impacts are more easily determined on a site-
specific basis. The Corps routinely conditions its permits for proper construction
methods when such conditioning is necessary.
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DEC-62 In actuality, the nearshore zone would be disturbed to a greater extent by pipeline
burial than any offshore disturbance by rig jack-up pads. During primary surface
hold drilling from a floating rig, these species would be subjected to discharges
and that portion of the stimulation returns that cannot be collected. The DEIS
addresses the impacts of these activities. The conclusions reached also apply to
those deepwater species listed in Table 3-2.
DEC-63 Comment noted. Errata, paragraph 4.213: change ''will be lower" to "could be lower."
By using a combination of selective cutting and herbicides, the quantity of herbi-
cide used is less than if only herbicides are used. The intent of the mitigation
reconmiendation is to reduce the potential hazard of herbicides on groundwater,
surface water, and biota. Also, it was noted in paragraph A.077 that by using
selective control rather than just herbicides, the result is a more diverse and
stable vegetation community.
DEC-64 Errata, Table A.l - Item SO: change Item 50 to Item 50a and add Item 50b. Item 50b
should read: Emergency plans are also required, under Part 255 of the New York State
Public Service Commission's Rules on Gas Safety.
DEC-65 Errata, paragraph D.011 (Item 3): Insert as first bulleted regulation—New York
Water Quality Standards, NYCRR Title 6, Chapter 10, §§700-704.
DEC-66 Appendix D, Part B (paragraphs D.008 to D.013), should have included a reference to
Article VII of the New York Public Service Law. The purpose of the Public Service
Law is the regulation of public utilities operating within the state. Article VII
deals with the requirements for certification of environmental compatibility and
public need for major electric and gas transmission facilities.
DEC-67 These comments address issues that can be resolved only after detailed further
consideration, with the concurrence of the involved federal and state authorities.
The proposed mechanism for resolution is the regulatory Task Force. The regulatory
Task Force, composed of representatives from federal and state governments, would
have ultimate responsibility for defining minimum federal and state standards to
guide offshore development. This DEIS, for the purpose of providing a framework for
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Job P/LERESl/p.13
discussion, contains a "Reference Program". It is not intended to suggest that the
Reference Program guidelines are in any way binding or are more than starting points
for the discussion. Each area and proposal will receive review on a case-by-case
basis and will be compared against the guidelines. In certain special cases where
there is an adequate demonstration of environmental acceptability, mitigation, and
lack of suitable alternatives, the potential to allow pipeline construction in some
of these areas could be considered. However, at the present time on a programmatic
level, our impact analysis indicates that these areas must be avoided to protect the
environment.
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NYHP-1 Comment acknowledged. The Corps will continue to coordinate the cultural resources
study with the State Historic Preservation Office and on a site-specific/proposal-
specific basis will coordinate in accordance with Corps regulations 33 CFR 320-239.
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DER-1 See Topical Response Number 3 on the Task Force and Federal Authority and Topical
Response Number 4 on the Offshore Program Office. The Reference Program and recom-
mended guidelines are minimum standards and do not negate more stringent standards
set by a state.
DER-2 See Topical Response Number. 1 on the Canadian Experience and Topical Response
Number 2 on Impacts of Accidents: Consideration of Canadian Experience.
DER-3 See Topical Response Number 3 on the Task Force and Topical Response Number 4 on the
Offshore Program Office.
DER-4 We are not aware of any statements from this office concerning blanket approval of
drilling permits by the federal government. Based on the potential impacts as
discussed in the DEIS, the need to protect water quality and public health and
safety, and the need for proposal-specific and site-specific analyses, both the
Corps and the Great Lakes National Program Office of the USEPA do not believe that
blanket permission to drill on the federal level is in the best public interest.
The federal agencies also have a responsibility to monitor and enforce the condi-
tions of their permits.
DER-5 In the Reference Program, it is assumed that the states would develop their own
requirements for competitive bidding, rental fees, bonds, royalties, and other
financial matters (paragraph 1.065). The more uniformity there is between the state
leases, the less chance there would be for disincentives to operators to lease from
one state as opposed to another (paragraph 1.060).
DER-6 Refer to Topical Response Number 3 on the Task Force and Federal Authority concerning
the need for federal permits. The form of Corps of Engineers permits is contained
in existing regulation 33 CFR 320-329. The DEIS did not state that local agency and
public concurrence is needed to issue a permit. Rather, in paragraph 1.071 it was
stated that no federal permit would be issued where Water Quality Certification was
denied or where Coastal Zone Management approved plans were not met. Further, no
federal permit would be issued where a federal, state, or local certification or
authorization had been denied; but the applicant could request reinstatement if that
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Job R/LERESl/p.2
authorization were subsequently approve'd. The views of local agencies and the
general public would be solicited and considered in the decision-making process. We
believe that the public interest review is necessary to obtain all relevant facts
and views of those who will be affected by the proposal. This public interest
review was essentially established in 1968 by the Corps, has subsequently been
upheld by the courts (introduction to Corps of Engineers regulations 33 CFR 320-329),
and was further supported by the enactment of the National Environmental Policy Act
of 1969 (NEPA). Sections 101(a) and (c) of NEPA describe the intent of Congress to
foster public input into the federal government's policies that affect the human
environment. Section 101(c) in particular states: "The Congress recognizes that
each person should enjoy a healthful environment and that each person has a responsi-
bility to contribute to the preservation and enhancement of the environment." The
notification procedures used by the Corps and other federal agencies in their public
review processes are intended to provide the public with the opportunities intended
by Congress.
DER-7 The DEIS does not propose any new federal regulations but is based on existing
federal regulations and acts of Congress. (See Topical Response Number 3 on the
Task Force and Federal Regulatory Authority.)
The comment does not specify which federal permits for onshore construction facili-
ties are in question. The Corps has no permit requirement for activities outside of
waters of the United States and adjacent wetlands. Applicable federal statutes
pertaining to onshore activities are existing and would include regulations promul-
gated in accordance with the Clean Air Act (PSD, NSPS, offsets, NAAQAs, etc.),
Resource Conservation and Recovery Act (RCRA), Clean Water Act (Sec. 404, 401, 402,
311, etc.), Safe Drinking Water Act, and others listed in the DEIS.
In regard to pipelines, the portion of pipeline from the wellhead to the Ordinary
High Water Mark (OHWM) of Lake Erie constitutes a structure and, thus, its installa-
tion requires a Section 10 permit. The portion from the OHWM to the processing
facility and beyond could be subject to U.S. Department of Transportation (USDOT)
requirements if the gas is marketed as a commodity through interstate commerce.
Since no determinations have yet been made by the states nor any concurrence from
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Job R/LERESl/p.3
the Federal Energy Regulatory Commission' received, we cannot rule out USDOT require-
ments. Again, these are existing authorities not proposed.
The drilling procedure and wells and wellheads constitute work or structures in or
under a navigable water and are subject to Section 10 permit requirements. The
substance "oil" is also classified under RCRA as a hazardous substance and various
other statutes related to oil (sections of the Clean Water Act) exist. The figure
of 5 gallons per day of liquid hydrocarbons relates to more than oil per se;
higher-chain hydrocarbons of natural gas such as aromatics are included, and many of
these are known toxic compounds. Appendix A of the DEIS shows that Pennsylvania
would require plugging of wells encountering oil, condensate, or wet gas. The state
of New York set a guideline limit of 5 gallons per day. Our review of Canadian gas
from Lake Erie indicates that most of the gas will contain less than 5 gallons per
day. As indicated in the footnote on page 1-21 of the DEIS, the 5 gal/day figure is
used in the Reference Program as an "indication of significant liquid hydrocarbon
production". In the event that gas development in Lake Erie were to be approved, an
actual upper limit could be established through leasing programs or standards set by
I
state or federal water quality agencies. Only careful data collection and record
keeping can provide the information necessary for ultimate determination of limits
on liquid hydrocarbon production. Table 1-10 also indicates that this figure is an
assumed state regulation. In regard to significance, the International Joint Commis-
sion (IJC) has recommended that there be no oil production and that wells containing
oil be plugged. They recommend production of dry gas only. The 1978 United States-
Canada Water Quality Agreement makes further statements about the significance of
oil but no numerical limit was set. Annex 8 of the Agreement indicates that the
discharge of harmful quantities of oil should be prevented. The term discharge
includes leakage and spillage. The IJC has defined harmful quantities as follows:
harmful quantity of oil means any quantity that, if discharged into clear calm
waters on a clear day, would produce a film or sheen upon, or discoloration of the
surface of the water or adjoining shoreline, or would cause a sludge or emulsion to
be deposited beneath the surface of the water or upon the adjoining shoreline".
Submerged pipelines and offshore drilling rigs and wells are mentioned as activities
to be considered. Currently, we do not believe that the recommended guideline is
unreasonable in establishing a starting point for consideration.
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DER-8 See Topical Response Number 4 on the Offshore Program Office.
DER-9 See Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on Impacts of Accidents: Consideration of Canadian Experience.
DER-10 See Response CSS-8.
DER-11 Foreign ownership or control of a company would not subject it to any special U.S.
regulatory requirements by reason of its foreign ownership or control.
A Canadian-owned facility operating in U.S. waters would be subject to all the
requirements applicable to any operations in U.S. waters. Any wastes classified as
hazardous wastes under Subtitle C of RCRA would be subject, at least with respect to
their generation and transportation in U.S. waters, to the RCRA hazardous waste reg-
ulations. Prohibitions on discharges of wastes into U.S. waters would also apply.
On the federal level, no indicaiton has been received that Canadian firms would
apply for permits to drill in U.S. waters or, if they were to drill, that they would
export their wastes to Canada. This eventuality, therefore, has not been investi-
gated in depth.
Shipment of wastes to Canada for disposal would be an international shipment. The
wastes if classified as Subtitle C Hazardous Wastes would, by reason of that classi-
fication, be subject to the requirements of Subpart E of the Part 262 Standards
Applicable to Generators of Hazardous Waste, 40 CFR §262.50 (1980). These require-
ments include notification to USEPA, conformance to USDOT container requirements,
confirmation of delivery to the foreign cosignee, and indentificaiton of port or
point of departure from the United States.
Drilling fluid wastes are now excluded from Subtitle C regulation; consequently, no
special RCRA requirements are imposed on their exports.
Other requirements, imposed by the U.S. and Canadian coast guards and customs offices
could apply to export of wastes to Canada. In addition, it is assumed that some
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Job R/LERESl/p.5
level of U.S. State Department and Canadian federal and/or provincial government
review and approval might apply, in particular to any shipment of hazardous wastes.
Transport and ultimate disposal of wastes in Canada is subject to Canadian environ-
mental laws and regulations. Canada would make its own determination as to what
wastes should be classified ¦ as hazardous. Canadian federal (as contrasted to pro-
vincial) regulation is confined, for the most part, to importation and transpor-
tation. For wastes not classified by Canada as hazardous, such regulation is
expected to be minimal.
Regulation of ultimate disposal of wastes is primarily under provincial jurisdic-
tion. Although Canadian waste control regulations are still under development, it
is expected that they will resemble, at least in a general way, those developed
within the United States.
References: phone conversations with John Skinner, Director of State Programs,
USEPA; Steward Hay, Acting Director, Waste Management, Environment Canada.
DER-12 To be provided.
DER-13 See Response EPA-4.
DER-14 Linkages between chloride loading in the Lake and chloride compounds used for road
deicing have been suggested by Ongley (1976), who also gives a figure of 8 x 104
metric tons for the annual loading of chloride in the lake, whatever the source.
From Table 1-32, a figure of 4.57 x 10® bbl (= 1.9 x 10® gal = 7.26 x io8 L) of
formation water is given as the total produced during the Reference Program, assuming
a 360-day production year. Chloride is the major anion reported in the formation
water at a concentration of 2.9 x 102 mg/L (paragraph 1.110). The total chloride
production for the whole Reference Program is then 2.11 x io11 mg or 2.11 x 102
metric tons, or almost three orders of magnitude less than the chloride loading for.
one year. The total salt production for the whole Reference Program and the annual
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Job R/LERESl/p.6
salt loading of the Lake from all sources are likely to be in approximately the same
ratio, so that formation waters produced by drilling for natural gas are not likely
to add significantly to the total salt loading of the lake. Although information is
given in Appendix E (paragraph £.007) concerning salt loading attributable to road
salting, the comparison of this information to gas development brines would not
change any of the conclusions reached in the DEIS. Improvements in lake water
quality are best served by limiting additional loading, especially when the additional
input can be feasibly avoided by collection, treatment, and disposal. In regard to
the 450 outfalls mentioned in this comment, the DEIS indicated that these discharges
must meet the requirements applicable to the facility type (e.g., effluent limita-
tion, performance standards, best available technology) and, again, comparisons to
gas development discharges would not be appropriate nor would it change the conclu-
sions reached in the DEIS. Each type of facility is analyzed with consideration to
available technologies, effluent limitations, etc. The effects of existing dis-
charges are accounted for in the baseline or ambient water quality.
DER-15 This value (5 bbl/MMCF of gas) was determined as" a worst-case condition based on
discussions with the Canadians.
DER-16 See Responses HHS-3 and D0I-7.
Contingency Flans and Cleanups,
and Topical Response Number 9 on
Additionally, see Topical Response Number 7 on
Topical Response Number 8 on Glycol Chlorination,
Water Supplies and Treatment Costs.
DER-17 See Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on Impacts of Accidents: Consideration of Canadian Experience.
DER-18
In paragraph 2.063, it was acknowledged that natural gas development in upland areas
will continue to be developed regardless of any lake program. See Topical Response
Number 11 on the Onland Alternative Program.
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DER-19 The DEIS assumes that an onland program' would be regulated by the three states and
23 counties in which development was occurring (paragraph 2.065). Also, all areas
in the 23-coun.ty region are potential sites for drilling (paragraph 2.067). In this
regard, the commenter is correct in stating that an onland program is more scattered
and that offshore development has a restricted ownership (three states). We made no
assumptions concerning the number of possible developers in the upland program, but
the asumption in the comment of fewer offshore operators is probably correct.
However, the alternatives section of the DEIS is explicitly designed around environ-
mental factors, not difficulties, associated with management of all the various
alternatives. Each alternative, including the Reference Program, would offer a
unique set of management possibilities and problems. Comparisons of management
scenarios for all alternatives is necessary only if the programs are unmanageable
and thereby infeasible. That is not the case for any of the alternatives discussed
in the DEIS.
DER-20 In the DEIS it is stated that various measures to mitigate the onland program, such
as revegetation, exist (paragraph 4.086) and potential problems with implementation
of the alternatives by developers are discussed. It is also noted that revegetation
must be successful to serve its purpose and that, until the new vegetation is estab-
lished, erosion will occur and wildlife habitat will be lessened. In the Terres-
trial Ecology section of Chapter Four relating to the onland program, it was not
stated that wildlife would leave and not return for the life of the project. Addi-
tionally, when new vegetation is planted in pipeline rights-of-way, it usually
constitutes a change in habitat type and will not necessarily provide suitable
habitat for the wildlife species that originally used the area.
DER-21 The impacts of upland development on stream water quality would result from various
materials such as hydrocarbons, muds, etc., and would be minor (paragraph 4.027).
The requested comparison would not change the conclusion reached in the DEIS.
Additionally, the types of pollutants in herbicides and pesticides are chemically
different from the types associated with upland gas development and, therefore,
comparison of volumes has little meaning in prediction of impacts.
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DER-22 Paragraph 2.012 is correct as stated.
DER-23 The Reference Program prohibits gas development in offshore sand and gravel areas
and with this prohibition there is no conflict. The state, however, may determine
that sand and gravel extraction should cease for gas development to occur and in
that case the state would stop leasing to sand gravel operators and issue no permits.
If the decision to deny permits is made by the state, then no Corps permits could be
issued to sand and gravel operators (paragraph 1.071). The decision on which resource
takes precedent is a state decision. We would point out that concurrent development
of gas and sand and gravel in the same area would not be compatible. The cutter
heads and clamshells used by various sand extractors could damage wellheads and
pipelines. We would see no problem with sand dredging over an abandoned well that
is properly plugged. We also see no significant problems associated with gas fields
being adjacent to sand and gravel areas, provided the gas field hardware is outside
the sand leasing boundaries and dredgers are aware that they shall not dredge outside
of the designated boundaries because of the presence of developed fields.
DER-24 The Lake Erie Interconnect Cable has been considered in the DEIS (see paragraph 3.137,
Table 3-6, and paragraph A.193); with proper planning of the lease sales there
should be no difficulty. The lead federal agency for development of an EIS on the
Interconnect Cable (U.S. Department of Energy) is also aware of the potential develop-
ment of gas in Lake Erie (see also comments from GPU). If both projects were
eventually approved, determinations could be made as to necessary buffer zones,
maintenance procedures, etc., for each project so that one would not affect the
other.
DER-25 There are some differences between staff and DER assumptions regarding the number of
tracts leased, wells drilled, and amount of gas produced over the life of the develop-
ment program. Staff assumptions have been modified to conform with state estimates
of leasing and drilling experience, cash bonus bids, and delay rental income. In
the revised calculations, state estimates of cash bonus bids, delay rental income,
and gas production have been used to calculate state income.
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The major difference between staff and state assumptions lies in the production
estimate of gas and its projected price. For 360-day and 288-day production
scenarios, the staff has estimated gas production over the life of the program to
be 147 and 118 BCF (from the lease areas in Pennsylvania), respectively, as compared
to the state's estimate of 90 BCF. The average price projection by the state over
the life of the program (1984t2011) is $5/MCF. This is a very low price projection
when imported gas is currently (1981) costing about $4.60/MCF. After 1985, when the
price of natural gas is completely decontrolled, the free market would equilibrate
the price of natural gas with its alternative fuels (e.g., #2 oil or #6 oil) on a
Btu basis. DRI, Inc. (Energy Review, Winter 1980-1981), forecasts a new contract
wellhead price of natural gas at $39.09/MCF in the year 2000. In the DEIS, the
staff used a conservative price estimate of $18.4/MCF in 2000 in calculating royalty
income of Pennsylvania. In 2011, the price is projected to be $45.76/MCF, assuming
a gas price rise at an annual rate of 9.9% over the period 2000-2011. For calcu-
lating gas revenue in the current analysis, an average price of $24.4/MCF over
1981-2011 has been assumed. Using the state's estimate of 90 BCF total gas produced,
the state's income over the life of the program will be as follows:
(1) Cash bonus bid income
(2) Delay rental income
(3) Royalty income ($90 x 10s
Estimated total income to
16.38 million
6.88 million
x 24.4 x 1/8) 274.5 million
state 297.76 million
The estimated income of the state here is higher than the staff's estimate in the
DEIS. This is due to (1) the state's higher estimate of cash bonus and delay rental
income, and (2) use of an average price of $24.39/MCF for the total production of
90 BCF. As more gas will be produced in the initial producing life of the well, in
actuality more than half of the total production will be sold at a lower price than
the average price of gas, and less than half will be sold at higher price than the
average. As a result, the amount of gas revenue using each year's price and produc-
tion will be less than what has been estimated here. The staff has used this method
of calculation for reporting income in the DEIS.
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Also, the assumption that 512 wells could be drilled is realistic. As seen in
Table 1-31, this occurs over a period of time and is performed by two rigs with an
average of 23 wells per year in Area IV and 27 wells per year in'Area V (see also
Table 1-18). This is not a prediction of how many wells will be drilled but how
many can be drilled assuming accelerated development. The assumption of maximum
development and accelerated development is necessary to assess worst-case impacts
and to take advantage of maximum use of cost data based on known trends (para-
graph 1.152). The Reference Program is not a prediction of future events but rather
a set of operational procedures frozen in time for purposes of analysis (para-
graph 1.020). Also, the economic feasibility analysis cannot predict operator
interest or other competitive aspects of development (paragraph 1.151).
We recognize that in making their own decisions concerning development, operators
may choose to be highly selective. However, basing assumptions solely on past
experiences may not accurately predict future events. Changing economies, fuel
availabilities, energy priorities, gas prices, and political considerations that
affect the energy situation may result in a change in operator patterns. The Lake
Erie leasing experience of 1959 and 1963 does not account for advances in technology,
changes in the economic and energy situation, new pricing regulations, and other
applicable changes that have occurred over the past 20 years. Interest in developing
resources has changed over that period of time. Resources once ignored by operators
are being developed in recent years.
Response to last paragraph of comment DER-25 (appropriate comments on the state's
projection of tens of millions of dollars as contained in the attachment) - To be
provided.
DER-26 The details of the cost considered for development of U.S. Lake Erie natural gas are
described in paragraph 1.156 and Appendix B. The costs of constructing underwater
pipelines and shore facilities are included in the total cost used in the economic
analysis of the Reference Program. The staff agrees that the cost of onshore trans-
portation of waste between dock and treatment disposal facility, not included in the
current analyses, should be included in the total cost of developing Lake Erie gas.
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Job R/LERESl/p.11
But, inclusion of this cost would not affect the economic decision of developing
U.S. Lake Erie natural gas. The present value gain from the production of gas from
the lease areas of New York, Pennsylvania, and Ohio are $282, 247, and $2017 million,
respectively. Even with a total disposal and treatment cost on the order of
$250 million, the present value of the operators of the development program would
increase by $2296 million, and. the program would still be economically viable.
DER-27 The staff's estimate of cumulative gas production from an average well in Clinton-
Medina gas reservoir over it's productive life of 20 years or more is 434 and
348 MCF, respectively, for 360- and 288-day production scenarios. These production
levels are only 87 and 70% of the state's estimate of cumulative gas production of
500 MCF per well. At the state's higher estimate of gas production, the economy of
the development program would be even more desirous than reported in the DEIS.
DER-28 To be provided.
DER-29 The DEIS relied on the following data sources: Ohio State has jurisdiction over
3457 mi2 of Lake Erie waters (Stevenson and Green et al. 1972). Pennsylvania has
jurisdiction over 735 mi2 and New York has jurisdiction over 594 mi2 (Sachs et al.
1981).
DER-30 The terminology used in the DEIS was derived from proposed lease requirements and
offshore rules and regulations of both New York and Pennsylvania (see para-
graph 1.085). In the analyses, a delay rental of one dollar per acre per year and a
drilling interval of about nine years for the lease areas in Pennsylvania was used.
If the rentals are paid on the lease areas for an average of seven years at a rental
rate of $3.00 per acre, the incremental delay rental cost to the operator will be
about $4.6 million which will not have any significant effect on the estimated
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Job R/LERESl/p.12
present value gain of $169 million for "Pennsylvania. Hence, the suggested delay
rental in Pennsylvania will not have any appreciable effect on the economic feasi-
bility of developing U.S. Lake Eries natural gas. Furthermore, because the assumed
percentage of royalty to be received for Pennsylvania is the same in the DEIS
economic analyses as suggested in the above contention, the result of the economic
analyses does not change.
DER-31 Pennsylvania's Bluff Recession and Setback Act [Pa. Cons. Stat. Ch. 85 (1981)] pro-
vides that municipalities must provide for the protection of those lakeshore areas
that have been designated by the Commonwealth's Department of Environmental Resources
as presenting a substantial threat to safety or stability of nearby existing or
future structures by reason of the rate of progressive bluff recession. The munici-
palities must adopt suitable land use, health, and other regulations to provide
standards for the location of structures or facilities in such bluff recession
hazard areas.
DER-32 We have reviewed the suggested changes cited in this- comment and have elected not to
change the titles of tables and verbiage in the paragraphs because the entire DEIS
is programmatic in nature, being based on various assumptions. There actually are
no proposed actions at this time. Thus, they are assumed wells, assumed procedures,
etc., and we are not predicting numbers of wells that will be drilled.
DER-33 As pointed out by the commenter, the statement on productivity of Clinton-Medicine
sandstones can be misleading. A more correct statement would read as follows: "...
the Clinton-Medina sandstones form an extensive deposit ... and will likely produce
gas throughout its extent where conditions are favorable. The favorable conditions
include a low-permeability caprock overlying relatively high-porosity zones."
DER-34 We have elected not to change the title of Table 1-1 because the entire document is
directed at the assessment of offshore Lake Erie gas development and we do not
believe that readers would assume the table includes offshore lands in, e.g., Lake
Ontario, Delaware Estuary, etc.
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DER-35 The Table Index and Table 1-5 should be titled "Estimated Production of Gas
per Average Well from Clinton-Medina Sandstones." The Table Index and Table 1-6
should be titled "Estimated Production of Gas per Average Well from Lockport Reefs"
(corrections underlined).
DER-36 Paragraphs 1.001 and 1.002 are parts of the introduction to the purpose and need for
the proposed action. The purpose and need for the proposed action relate to the
region of the United States bordering Lake Erie. The only reason that Canada was
even mentioned in these sections was to indicate that all three states are aware of
the Canadian activities and success and that this has, in part, led them to view
aspects of Lake development. The need and purpose of the Reference Program is not
influenced by the production from Canadian Lake Erie or by the two wells drilled
offshore of Pennsylvania.
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ODNR-1 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority.
ODNR-2 In paragraph 1.002, we had advised that Ohio policy concerning offshore gas develop-
ment is a matter of current legislative debate. The statement was not intended to
mean that Ohio does not have legislative authority to lease gas in Lake Erie. The
statement concerning debate was directed at various proposals in the Ohio legisla-
ture to reinstitute a ban on drilling. We simply intended to point out that
although the drilling ban had expired in 1978, the matter was brought up again in
1980. The legislation mentioned in paragraph S.010 pertains to that recommended by
the Task Force in regard to minimum uniform leasing procedures and the creation of
an Offshore Program Office in the states.
ODNR-3 See Topical Response Number 4 on the Offshore Program Office. The offshore office
is recommended as an administrative tool to provide coordination of the overlapping
regulatory requirements. It is not a federal directive.
ODNR-4 In satisfying requirements to prepare a detailed statement under Section 102(2)(C)
of the National Environmental Policy Act (NEPA), the DEIS does so on a programmatic
level. This should not be interpreted as meaning that all NEPA requirements for
future applicants have been satisfied.
0NDR-5 Statement noted.
ONDR-6 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority,
which provides the reasons for suggesting standard forms.
ONDR-7 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority,
and Topical Response Number 4 on the Offshore Program Office.
ODNR-8 Should gas development in U.S. Lake Erie ultimately be found environmentally accept-
able in principle and should sufficient interest be demonstrated by potential oper-
ators and states, the Buffalo District would review various minor activities associ-
ated with gas development to determine the applicability of general permits and
would investigate possible joint processing procedures with the states.
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Applications would be reviewed to dete'rmine any activities that fall under the
criteria of nationwide permits. Some activities associated with gas development—
such as pipeline crossings of streams, minor shore protection, etc.—could poten-
tially qualify under the criteria for nationwide permits. Nationwide permits are
contained in Corps of Engineers regulations 33 CFR 320-329 as promulgated by the
Office of Chief of Engineers. The District Engineers do not have the authority to
promulgate nationwide permits.
ODNR-9 To be provided.
0DNR-10 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority,
and Topical Response Number 4 on the Offshore Program Office.
0DNR-11 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority.
The director of natural resources--with the approval of the director of environ-
mental protection, the attorney general, and the governor—may issue permits and
make leases to parties ... to take and remove ... oil and other minerals or other
substances from and under the bed of Lake Erie (after July 1, 1978). Permits run
from 1 to 10 years [Ohio Rev. Code Ann. §1505.07 (Page)].
ODNR-12 The offshore office was recommended as an administrative tool and its establishment
does not override existing agencies authority to issue permits. See Topical
Response Number 4 on the Offshore Program Office.
ODNR-13 The drilling seasons listed in the DEIS are premised on prohibiting offshore activi-
ties when there is a significant chance of hazardous seasonal weather. The opening
dates conform with reported average navigation season beginning dates for Buffalo
and Cleveland harbors. Closing dates are based on increased potential for severe
storms in November. In the absence of preliminary offshore operational regulations
in Ohio, the state was assigned the same season as Pennsylvania. Much of the
inflexibility in seasons is created by ambient weather conditions (e.g., ice condi-
tions, storms, atmospheric instabilities caused by the Lake during the late fall).
The suggested seasons should provide sufficient drilling time while also providing
accident protection. If future information substantiates the acceptability of
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Job S/LERESl/p.3
different drilling seasons, revision could be considered. See Topical Response
Number 10 on the Reference Program Concept.
ODNR-14 On page 6 of the Clifford (1975) report, the author did not conclude that oil would
be found in Clinton-Medina but that Ohio production would be primarily gas with
little oil or water. On page 7, he stated that a contrary opinion is held by some
geologists in Ontario. The Reference Program would not allow the development of oil
in Lake Erie.
ODNR-15 Although the hazards cited are usually associated with drilling activity, they are
related either directly or indirectly to a number of geologic processes. Perhaps
more appropriately these hazards could be labeled "geology-related hazards".
ODNR-16 The state of Ohio holds the mineral rights beneath the Lake offshore of Ohio and has
the option of balancing one resource against the other. The state may, at its
option, prohibit development of these areas.
ODNR-17 See Topical Response Number 4 on the Offshore Program Office. The necessary techni-
cal expertise would remain in the appropriate state permitting agency. The offshore
office is a coordinating office.
ODNR-18 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority.
Development of uniform minimum standards would still allow latitude for each state's
particular concerns. From the standpoint of resource development, it would appear
that all three states have similar concerns and interests. Based on the comments
received on the DEIS from all three states, it also appears that they share common
goals of environmentally safe extraction of gas resources from the Lake. The common
goals and concerns provide an excellent base upon which to initiate uniform procedures
ODNR-19 Table 1-10 along with Table 1-7 essentially form the framework of the Reference
Program. The cited Table 1-10 assumes the adoption of many of the Reference Program
guidelines contained in Appendix D of the DEIS.
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Job S/LEBESl/p.4
0DNR-20 The ultimate destination of natural gas produced from Lake Erie is not known at this
time. However, if the gas enters a pipeline in Ohio, is comingled with interstate
gas, and then leaves the state, it is generally considered interstate gas and is
under the jurisdiction of the Federal Energy Regulatory Commission (FERC). The
final decision on whether the gas is inter- or intrastate natural gas will have to
be made by FERC.
ODNR-21 To be provided.
ODNR-22 The economic advantages of exploring and producing from the Lockport reefs rather
than the Clinton-Medina sandstones relates to the superior production character-
istics and success ratio of the reefs and not to their overall extent or long-term
production potential. These advantages and other pertinent discussions (including
evidence on which the reefs were defined) can be found in the following paragraphs
in the DEIS: 1.033, 1.034, 1.046, 1.087, and 1.093.
The point was also made that there is an apparent discrepancy between lease areas
shown on Figure 1-1 (14) and those discussed in the text (16). There is no discrep-
ancy because Lease Areas XIII and XIV in Lockport will, when depleted, be redrilled
to the Clinton-Medina sandstones and be reassigned as Lease Areas XV and XVI (see
also paragraph 1.101 and footnotes "e" and "f" on Figure 1-18).
It may appear misleading, but the generalized locations of potential Lockport reef
structures were based on a number of factors as discussed in detail in para-
graphs 1.034-1.036, and 1.092. It is well documented throughout the draft that this
is a "reference" program based on a number of assumptions, including those for gas
resource location and production estimates. They are not intended to be considered
absolutely accurate.
The seismic survey was not performed for the Corps, USEPA, or Argonne (the seismic
survey was performed by Petty-Ray Geophysical Operations, Houston, TX—para-
graph 1.092). Petty-Ray is aware of the use of our interpolation, did not object to
its use, and did not comment on our interpolation. Ultimate definition of location
belongs to the industry and states. The Corps and USEPA are not oil and gas develop-
mental agencies.
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ODNR-23 See Topical Response Number 2 on Impacts of Accidents: Consideration of Canadian
Experience.
ODNR-24 The staff agrees that the cost of onshore transportation of waste between dock and
treatment disposal facility should be included in the total cost of developing Lake
Erie gas. But, inclusion of this cost would not affect the economic decision of
developing U.S. Lake Erie natural gas. The present value gain from the production
of gas from the lease areas of New York, Pennsylvania, and Ohio are $282, 247 and
2017 million, respectively. Even with a total disposal and treatment cost on the
order of $250 million, the present value of the operators of the development program
would increase by $2296 million, and the program would still be economically viable.
ODNR-25 Comment noted.
ODNR-26 Comment noted. Unless specifically prohibited by the state, we have assumed the
potential for use of trawl nets in the future and have recommended use of deflectors.
This is consistent with the worst-case analysis performed for the Reference Program
(see also Response DOI-17).
0DNR-27 Information update noted. The information is correct as referenced and the impact
assessment remains unchanged with the new information.
ODNR-28 Intermingling of aquifers in the vicinity of old wells will locally degrade water
quality of aquifers beneath Lake Erie. Although the area of Lake Erie under con-
sideration has no potable rock aquifers, the potential for further water quality
degradation of the aquifers does exist, regardless of their current use. The pre-
glacial buried valley underlying the Lake may be contaminated if failure of the
proposed 16-inch drive pipe casings were to occur. In this case, degradation of the
fresh water contained in this aquifer would result.
ODNR-29 See Response DEC-8.
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Job T/LERESl/p.l
0HP0-1 Comment noted. The Buffalo District will coordinate the cultural resources techni-
cal report with the State Historic Preservation Office and appropriate regional
offices. Coordination regarding specific applications would also be accomplished in
accordance with Corps of Engineers permit regulations 33 CFR 320-329.
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Job U/LERESl/p.1
NYPR-1 The statement concerning leasing of state parks for natural gas development is
noted. Although the leases will likely result in considerable quantities of gas,
the regional gas situation as described in the DEIS and this Final EIS would still
remain that of a net importer (refer to Topical Response Number 12 on the Need for
Natural Gas). See Topical Response Number 10 on the Reference Program Concept and
Topical Response Number 11 on the Onland Alternative Program. The Lake Erie
Reference Program would not affect or be affected by the state park leasing program.
NYPR-2 The DEIS contained a generalized land-use map of the shoreline (Figure 3-3) showing
broad areas generally used for agriculture, recreation, public use, etc.,; however,
due to the extent of the Reference Program area and the large number of facilities
in the three states, no attempt was made to show all the specific facilities for
recreation. If gas development is found environmentally acceptable in principle and
if applications are received, each specific proposal would be reviewed. At the time
of specific proposal review, those recreational facilities in the potential impact,
area would be identified and coordination with the state would occur. The maps on
documents submitted by New York State Parks and Recreation will prove useful during
the review of applications.
NYPR-3 See Response NYHP-1.
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CCD-1 Comment noted.
CCD-2 See Response CCD-7.
CCD-3 We have projected that, for the Reference Program, four work ports would be needed
to handle an estimated 25 vessels, eight of which are drilling rigs (see para-
graph S.036). At the current programmatic level of study, there is no indication
that smaller ports would be used by operators. It is more likely that operators
would choose to maintain their facilities in close proximity to one another in major
ports since the major ports would require less modification than smaller ones.
Scattering their operations along the shoreline would tend to hinder the operations.
However, given the total number of vessels projected for the program, any use of
smaller harbors would create only minor impacts. Some of the locational constraints
that pertain to Reference Program facilities are given in Table 1-34. There are
constraints that would lead to the conclusion that operators are likely to centralize
operations in major ports. In regard to emergency conditions, see Topical Response
Number 7 on Contingency Plans and Cleanups.
CCD-4 It is our understanding that the incident cited in this comment involved the strand-
ing of five individuals in stalled boats in the ice off Dunkirk in 1978. An emer-
gency of this type would not be covered under any pollution cleanup procedures of
the federal or state governments. However, the cited incident is given only as an
example to point out potential local costs of cleanup during an emergency. See
Topical Response Number 7 on Contingency Plans and Cleanups.
Additionally, among the responsibilities of the proposed regulatory Task Force is
that of recommending a minimum set of federal and state standards. It would be the
responsibility of the Task Force to recommend how monitoring and enforcement deci-
sions should be made, whether local land-use controls should be reevaluated, whether
existing emergency systems should be augmented, and how the burdens of the program
on local communities should be distributed.
CCD-5 According to pipeline maps of the Lake Erie region, the area is well served with a
dense network of natural gas pipelines. Some additional transmission lines may have
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to be constructed depending upon the location of production fields, gathering lines,
and onshore lines; but the exact number or extent of these additional pipelines
cannot be determined at this time.
CCD-6 See Response DOS-1, Topical Response Number 8 on Glycol Chlorination, and Topical
Response Number 9 on Water Supplies and Treatment Costs.
CCD-7 See Response EPA-1.
CCD-8 The recommendation is acknowledged. The subject of royalties and other fees associ-
ated with mineral development is not within the regulatory jurisdiction of the
federal government in regard to Lake Erie. Development in Lake Erie--in which the
states own the mineral rights and can collect royalties, lease fees, etc. — is
different from development on federal land.
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CEH-1 Requirements aad procedures to ensure proper handling, treatment, and disposal of
residuals generated and materials used are outlined in the Reference Program.
Appendix D of the DEIS indicates that the operators would be required to provide the
strategy for waste handling to the agencies and that monitoring would be required.
The environmental effects associated with the Reference Program are presented.
CEH-2 Where state authorization is required for the same activity covered by Corps permits
and that state authorization is not granted, the Corps permits would be administra-
tively denied without prejudice to the right of the applicant to reinstate processing
if subsequent approval is received (paragraph 1.071). Thus, applicants would have
to obtain the state permits and leases necessary for gas development activities.
CEH-3 Statement of position is noted. As indicated in Response CEH-1, the Reference
Program requires waste disposal strategy submittal by applicants and monitoring.
The requirements of the Resource Conservation and Recovery Act (RCRA) regulations
and the Safe Drinking Water Act, would also apply to disposal activities. Proper
solid and liquid waste-disposal sites can only be determined during the site-
specific/ proposal-specific analyses. However, possible suitable host formations
for underground injection and the criteria for hazardous waste disposal according to
current interpretation of RCRA requirements are discussed in the DEIS (see para-
graphs 1.102 to 1.130 and Tables 1-11, 1-12, and 1-32).
CEH-4 See Topical Response Number 7 on Contingency Plans and Cleanups.
CEH-5 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority.
Administratively, establishment of any Task Force prior to the Final EIS is not
possible. First, a decision concerning environmental acceptability in principle
must be made. The public is being offered input into guidelines through the review
and comment procedures for this EIS. Public input also included the concerns raised
during the formal public hearings which were held prior to the writing of the DEIS.
CEH-6 See Response CCD-4.
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CEH-7 As indicated in Response CEH-3, the strategy for waste disposal would be part of the
leasing and permitting requirements of the program. We assume that operators would
seek or construct facilities within a reasonable distance of their operations to
reduce costs and work delays.
CEH-8 The 15-day time frame is the time it would take to move a rig in and drill a relief
well. This period is slightly longer than the time to drill an ordinary well since
the relief well would have to be directionally drilled, which takes more time than
conventional drilling. Additionally, the drilling season has been designed to avoid
poor "end of the season" weather conditions. Additionally, see Response ODNR-13.
CEH-9 The probability of causing or triggering earthquakes by developing gas resources
beneath Lake Erie is considered low. This is based on historical seismicity records
and on natural gas production experience in the Canadian program which, incidentally,
has not been linked to seismic activity. Due to the absence of any major identified
faults in the Lake Erie Basin, the potential for significant and/or damaging seismic
activity is negligible. Further discussion of seismicity in and around the Lake
Erie Basin can be found in the DEIS (paragraphs 1.053 through 1.056).
The probability of an earthquake in this area being caused by natural gas removal
operations is so low that it would undoubtedly be extremely difficult, as a matter
of law, to support a claim for earthquake damage due to such operations. For this
reason, insurance would appear to provide the best mechanism to reimburse for any
earthquake losses that might occur.
CEH-10 Pennsylvania operational rules and regulations delineate the term of its permit as
April 1 through October 31 (Table A.l, Item 19c). The question of equipment in
transit or other variances is best interpreted by the Pennsylvania Department of
Environmental Resources. Similar regulations have been proposed for New York.
Some repair of underwater equipment in Canadian waters has been performed during
periods of ice cover. Ice can form as early as December, thus providing a minimum
of one month for maintenance activities requiring ice-free conditions. November is
a stormy period and repair activities could be hampered by surface conditions. All
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developmental activities require written permission of the Pennsylvania Department
of Environmental Resources (Table A.l, Items 19a and 19b).
CEH-11 See Topical Response Number 8 on Glycol Chlorination.
CEH-12 The dissolved solids in the brines end up in the solid waste fraction after proces-
sing at the onshore treatment/disposal facility (see Figure 1-16). The presence of
lead, cadmium, copper, or other metals or materials in the brine need not cause any
major changes in the waste management scheme presented in Figure 1-16 because a RCRA
hazardous waste landfill for the solid waste fraction of the brines is already
assumed as part of the waste disposal scenario. If the constituents from the brine
render the solid waste fraction hazardous, a secure hazardous waste landfill may be
required. (Note that according to 40 CFR 261.4, these wastes are, at present,
exempt from the hazardous waste designation under RCRA, but the states may promul-
gate regulations with more stringent definitions.)
CEH-13 With regard to the recommendation by the Erie County Health Department that the
industry prove the degree of hazard of these wastes, it should be pointed out that
Congressional amendments to RCRA would provide for a study of these wastes by the
USEPA. (See the Environment Reporter, May 18, 1979: 78-79. House, Senate Panel
Amend, Reauthorize RCRA.)
CEH-14 The mention of sites 150 miles from shore (paragraph 1.22) was an indication of
where these types of sites are located. It was not intended as an assumption that
operators would haul wastes this distance.
CEH-15 See Response ODNR-16 and Response PFC-7.
CEH-16 See Response DOI-17.
CEH-17 The purpose of Appendix C is to present the assumptions used for dispersion modeling.
The assessments of worst-case accident scenarios were presented in Chapter Four.
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Erie County should not be affected any'differently than other shoreline counties.
Some minor effects may occur with regard to recreational use of beaches, visual
esthetics, and an increased risk to recreational boating (paragraph S.035), but the
overall economic effect is expected to be beneficial on balance (paragraph A.226).
CEH-18 See Response EPA-5.
CEH-19 Capsize of a stimulation barge could result in discharge of up to 15,000 gallons
(approximately 57,000 L) of 15% hydrochloric acid to Lake Erie. The pH of the water
near the discharge point would depend upon the discharge conditions. A calculation
based upon conservative assumptions gives a pH value of approximately one within a
few meters of the release point. Assuming a current speed of 55 cm/s, very conser-
vative for depths at which water intakes are located, acid could be transported
0.5 mile within approximately 24 minutes. Again using worst-case assumptions, the
pH value of the water at an intake would be no more than 0.5 pH unit below the value
for ambient water. Ambient pH values in Lake Erie epilimnetic water are usually
about 8. The maximum number of fish that could be killed is not possible to
estimate.
CEH-20 Impacts to deep host formations that will receive formation water injections are
expected to be minor inasmuch as they already contain saline and mineralized waters
of natural origin. Secondly, the volume of fluid to be injected is relatively small
and, thirdly, there is a great thickness of low-permeability intervening formations
between the host formaton and accessible potable water. This is also discussed in
paragraph 4.009 of the DEIS.
Potential releases of injected industrial wastes as a result of penetration by
drilling activities will be controlled through required drill casing and well
development techniques and equipment designed to control such occurrences. These
techniques and equipment are described in the section on "Routine Activities"
(pages 1-53 through 1-74), including step-by-step procedures listed in Table 1-25.
Formation waters are naturally occurring and relatively harmless; they are consider-
ably less toxic than the industrial wastes that have been injected into deep forma-
tions. Thus, even if its reservoir were penetrated, the resulting impacts would be
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relatively minor and of short duration. Additional discussions of formation waters
and their disposal can be found in paragraphs 1.110, 1.113, 1.126-1.131, and 4.009.
Correction to commenter's letter noted.
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STW-1 On an application-specific basis, the Corps would advise the general public of the
proposals by public notice. The public notice describes the proposed work and
proposed locations and requests the comments and views of the general public and
federal, state, and local agencies. Additionally, the permit processing procedures
allow for public hearings on proposals. In cases where an EIS is required, the
scoping meetings would allow for public input.
STW-2 See Responses EPA-4 and STW-1. The transport of wastes from the onshore treatment
facility to the landfill is most likely to be by dump truck or, for the small amount
of oil waste (see paragraph 1.125), tank truck.
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CCH-1 See Topical Response Number 9 on Water 'Supplies and Treatment Costs and Topical
Response Number 8 on Glycol Chlorination. Actually, these supplies would have more
/
than 0.5 mile buffer if they did not extend far into the Lake because they would be
covered by the one-mile shore buffer.
CCH-2 See Topical Response Number 6 on Sediment Resuspension, Topical Response Number 8 on
Glycol Chlorination, and Topical Response Number 9 on Water Supplies and Treatment
Costs.
CCH-3 General requirements for the geologic strata utilized for deep well injection are
discussed in paragraph 1.130. Further details may be found in the reference cited
there. See Response EPA-4.
CCH-4 Should gas development in Lake Erie ultimately be determined environmentally accept-
able in principle and should applications for Corps permits be received for drilling
offshore of Chautauqua County or in areas that could affect the county, the Buffalo
District would ensure that the Health Department is provided the opportunity to
comment on specific proposals.
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CEPX-1 The assessment of an onland alternative'was for environmental comparison only. The
Reference Program must be judged on its own merits and on consideration of its
administrative procedures. The recommendations made in the administrative section
of the DEIS (Chapter One) and in the guidelines section (Appendix D) are designed to
ensure that the environment is protected and that proper monitoring and enforcement
occur. (See also Topical Response Number 3 on the Task Force and Federal Regulatory
Authority.) The Reference Program projects about eight rigs, that locations of
activities will be known, and that fewer personnel would therefore be required to
monitor an offshore program than an onland program which is highly scattered in the
region. The offshore program is subject to various federal authorities which the
onland program is not.
CEPX-2 Recommendations noted. This programmatic DEIS recommends the adoption of uniform
environmental standards by the three states. Additionally, no federal permits will
be issued where a state has denied its authorization to perform the work.
CEPX-3 The states own the mineral rights beneath the Lake, and the establishment of royal-
ties and the use of the monies is not a federal but a state decision. Financial
support for the administrative procedures on a state level would originate from
operator payments to the states as stipulated in lease provisions (paragraph 1.068).
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CEXN-1 See Topical Response Number 3 on the Ta'sk Force and Federal Regulatory Authority.
Water quality certification that is issued under Section 401 of the Clean Water Act
for an activity that may affect the waters of an adjacent state is subject to review
by the USEPA and the potentially affected state.
CEXN-2 The preparation of this Programmatic DEIS does not negate a proposal-specific review
«
of individual applications. As indicated in various sections in Chapter One and
Appendix D of the DEIS, there would be numerous environmental review requirements
and the need for site-specific and more detailed program-specific information. This
information would be used to assess the environmental impacts of each proposal in
more detail. Examples of the types of reviews that would be performed on specific
proposals include: permit reviews under Section 402 of the Clean Hater Act
concerning discharges into the waterways; Water Quality Certifications under Sec-
tion 401 of the Clean Water Act; Prevention of Significant Air Quality Deterioration
permit reviews (see Chapter Four—Air Quality); reviews and testing under Resource
Conservation and Recovery Act (RCRA) regulations for waste disposal; reviews under
the Safe Drinking Water Act; Corps of Engineers permit reviews under Section 10 of
the River and Harbor Act of 1899 and Section 404 of the Clean Water Act; Spill
Prevention and Accident Contingency plan reviews; and others listed or discussed in
the DEIS (see paragraphs 1.069 to 1.073, 1.076 to 1.084, and Appendix D). All of
these reviews would require detailed review of specific proposals to ensure the
protection of water quality and supplies, groundwater, air quality, shore erosion,
aquatic habitat, recreation, endangered species, and other public interest factors.
CEXN-3 See Response CCD-4.
CEXN-4 See Topical Response Number 12 on the Need for Natural Gas.
CEXN-5 A public meeting was held in Buffalo, NY, on 11 February 1981 concerning the Draft
Programmatic E1S. See public involvement section of this Final EIS.
CEXN-6 The effects of routine and accidental releases on potable water supplies are discus-
sed is some detail in the DEIS, particularly in paragraphs 4.017-4.025 and
4.071-4.074, and in Appendix C. The staff maintains that impacts were adequately
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Job A/LERES2/p. 2
assessed at the programmatic level. Site-specific impacts may be addressed in
site-specific environmental impact statements. Additionally, see Topical Response
Number 8 on Glycol Chlorination and Topical Response Number 9 on Water Supplies and
Treatment Costs.
CEXN-7 See Topical Response Number 12 on the Need for Natural Gas.
CEXN-8 See Response CCD-7. This programmatic DEIS does not negate proposal-specific review
or propose any blanket authorization for future activities.
CEXN-9 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority.
This programnatic DEIS and the hearings which were held in connection with the
project were the first stages in gaining public input for the program. If gas
development in U.S. Lake Erie is ultimately determined environmentally acceptable in
principle and if applications are received, the public would be afforded additional
opportunities to comment on specific proposals.
CEXN-10 Sensitive public and natural areas have been identified as constrinats for U.S. Lake
Erie natural gas resource development. Site-specific identification and prohibition
of development in these areas would be addressed in site-specific environmental
impact statements for natural gas development.
Additionally, there is an environmental sensitivity analysis to be performed on a
site-specific basis (Corps of Engineers permit review includes considerations of
erosion, fish and wildlife, wetlands, water quality, and other public interest
factors (see Tables 1-13 and 1-14).
CEXN-11 The DEIS defines induced employment as new jobs generated when direct and indirect-
employees spend money in the region and operators purchase goods (paragraph 4.166).
For example, more workers in the area would induce a need for more doctors and
clerks to serve them.
CEXN-12 The DEIS acknowledged the problem associated with availability of disposal sites and
indicated that operators may have to construct their own facilities. Any new facili-
ties would have to comply with RCRA regulations (see paragraphs 1.120-1.131 and
paragraph 1.133).
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CEXN-13 The suggestion concerning money received by states during leasing is noted. However,
the mineral rights beneath Lake Erie belong to the states, and the use of funds
obtained because of these rights is determined by the states not the federal govern-
ment. Additionally, see Topical Response Number 7 on Contingency Plans and Cleanups
and Topical Response Number 9 on Water Supplies and Treatment Costs.
CEXN-14 See Response CEXN-6.
CEXN-15 The Reference Program guidelines are presented as a starting point for discussing
the environmental impacts of an offshore development program. They are not, nor can
they be, binding on any governmental authority—federal or state. They do provide a
basis for development of standards by an intergovernmental regulatory Task Force.
Definitive evaluation of potential impacts cannot be performed until regulations
have finally been promulgated and specific proposals for offshore activity have been
submitted. In the interim, the Reference Program provides a conceptual framework
permitting tentative estimates as to the potential impact of an offshore drilling
program.
CEXN-16 See Responses CEXN-15 and EPA-1.
CEXN-17 See Response CCD-4.
CEXN-18 Potential for accidents between gas drilling and commercial/recreational boating
activity is addressed and measures to prevent such accidents are identified (para-
graph 4.066).
CEXN-19 An analysis of the "national supply system" is beyond the scope of the DEIS. The
need for natural gas within the industrial sector in the Lake Erie region' was
addressed (see paragraph 1.018, pages 3-47 to 3-50, and page 4-63. If Lake Erie gas
is produced, there is no guarantee that Erie County end users will directly benefit
from the development of that resource, although the gas would most likely be utilized
in the area. The price of natural gas to Erie County consumers will probably not be
affected very much by Lake Erie gas production due to "rolled in pricing." See also
Topical Response Number 12 on the Need for Natural Gas.
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Job A/LERES2/p. 4
CEXN-20 Statement of position noted.
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Job B/LERES2/p. 1
ENC-1 Based on the analysis of impacts on fish and wildlife, recreation, and water quality
as discussed in the DEIS and in consideration of the objectives of the Clean Water
Act (CWA), we do not agree that the Reference Program is inconsistent with the goals
of the CWA. The Act itself declares that a goal is the elimination of the discharge
of pollutants into navigable waters [Section 101(a)(1)] and that, wherever attain-
able, an interim goal is to be achieved of water quality that provides for the
protection and propagation of fish, shellfish, and wildlife and for recreation in
and on the water. The goals of the Act are implemented by Section 301 which states
that such discharges are unlawful except in compliance with Section 301, 302, 306,
307, 318, 402, and 404 of the Act. Sections 402 and 404 in turn authorize the
permitting authorities to allow certain discharges if they comply with the appro-
priate guidelines, limitations, and standards. Section 301 (effluent limitations),
Section 302 (water-quality-related effluent limitations), Section 306 (national
standards of performance), Section 307 (toxic and pretreatment effluent standards),
Section 404(b)(1) (guidelines for the specification of disposal sites for dredged or
fill material), and Section 318 (aquaculture) relate to these criteria for permits.
The statutory scheme makes it clear that discharges shall not take place until they
have been found acceptable. The CWA permit regulations, standards, and guidelines
are applicable to gas development activities in Lake Erie and compliance with these
constitutes compliance with the goals of the Act. The Reference Program is limited
to the smallest possible releases and is judged under the CWA in the DEIS. Under
Section 208 of the Act, appropriate areawide mechanisms related to Sections 402
and 404 are provided.
ENC-2 See Topical Response Number 8 on Glycol Chlorination and Topical Response Number 9
on Water Supplies and Treatment Costs.
ENC-3 It was stated in paragraph 3.066 that the only procedure for removal of high concen-
trations of total dissolved solids is coagulation using an increased dosage of alum,
that removal efficiencies are low, and that an acceptable level of TDS is on the
order of 500 mg/L. Additionally, see Topical Response Number 9 on Water Supplies
and Treatment Costs.
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Job B/LERES2/p. 2
ENC-4 See the following Topical Responses: Number 6 on Sediment Resuspension; Number 7 on
Contingency Plans and Cleanups; and Number 9 on Water Supply and Treatment Costs.
Also, the disclosure requirements for the program- and site-specific analyses will
provide further refinement of impacts.
ENC-5 See Response ENC-1. Although the Clean Hater Act calls for areawide waste treatment
management and publically owned sewage treatment in the effort to meet the goals of
the Act, this should not be interpreted to mean that other programs which meet the
mandate of the CWA through other provisions such as Section 404 and 402 permits are
counterproductive. Congress clearly intended to allow certain acceptable discharges
by the inclusion of these provisions in the Act.
ENC-6 Although the processing facilities would be new uses, the pipelines are not neces-
sarily new because the area is served by existing pipelines. The coastal zone also
currently includes industrial facilities of much greater magnitude than the proces-
sing and compressor facilities such as power facilities and industrial facilities.
The coastal zone management (CZM) proposal by the state does not rule out siting
these facilities in the coastal zone but advises of detailed analyses to be performed
under Article VII of the New York Public Service Law, which includes coastal zone
land-use considerations. The DEIS advises site-specific studies when appropriate.
See Response EPA-1.
ENC-7 The Reference Program was analyzed in terms of its potential land-use, esthetic, air
quality, water quality, recreation, and water-use impacts. Although some land-use
conflicts may occur, there is no indication that the Reference Program would signi-
ficantly disrupt current land-use patterns or result in any cutbacks in nonindustrial
projects. Given the facility setbacks and the small coastal area affected by land-
falls, the impacts are expected to be minor. Development will be consistent with
local zoning and CZM plans.
ENC-8 As indicated in paragraphs 4.143 and 4.146, the drilling rigs are nonpermanent
drilling platforms and cannot be located closer than one mile from the shore. The
impact on residential land users is expected to be negligible.
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Job B/LERES2/P- 3
ENC-9 Although residential areas along the Lalce could be affected by the siting of produc-
tion facilities and possibly waste disposal facilities due to a lowering of neighbor-
hood amenity levels (the attractiveness and value of real estate), the degree to
which this could occur is currently uncertain and will depend in part on the areas
ultimately selected as possible sites. Properly designed and screened facilities
located in areas of low population should have very little effect and, if located in
4
commercially or industrially zoned areas, the effect on property values could be
beneficial. Production facilities should be located away from densely populated
areas (Table 1-34; paragraph D.034); if it is necessary for operators to construct
their own waste facilities, these facilities would be ideally located as close as
possible to their other facilities which would be near major ports. The location of
these facilities on a proposal-specific basis would be subject to careful siting
suitability analysis in accordance with federal, state, and local land-use and
environmental laws (Table 1-34). The siting suitability analysis should further
ensure that residential property values are considered. See Response EPA-1.
ENC-10 The esthetic impacts of the Reference Program are discussed in paragraphs 4.137-
4.152. Impacts on sport fishing and recreation are contained in paragraphs 4.061
and 4.059, respectively. The conclusions reached in the analyses are that the
esthetic impacts on the shoreline would be slight, that no detectable impacts to
Lake Erie fish populations are expected, and that recreation impacts would be slight.
The analysis resulted in no evidence that would lead to a conclusion of negative
impacts on tourism.
ENC-11 Impacts to water quality and aquatic organisms during accidents would be local and
insignificant on a lakewide basis and in many instances the effects would be
temporary (paragraphs 4.023, 4.025, and 4.057). Based on these conclusions, there
is no evidence that accidents would have long-term effects on the viability of
recreational and commercial industries that are tourist-related.
ENC-12 This is a restatement of discussions contained in the DEIS. No response required.
ENC-13 Areas prohibited under proposed state regulations are noted. The Reference Program
prohibits drilling within one-mile of the shoreline and 0.5 mile of water intakes.
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Job B/LEKES2/p. 4
ENC-14 The concerns not mentioned in the draft' CZM plan have been considered in the DEIS.
The Reference Program guidelines include consideration of landfall and processing
plant siting constraints and the need for site-specific suitability analyses. See
Response EPA-1.
ENC-15 The CZM goals are noted. They are in agreement with the conclusions reached in the
DEIS. The Reference Program guidelines, buffer zones, and recommendations for
site-specific analyses include consideration of the items listed in the comment.
See Response EPA-1.
ENC-16 The proposed CZM plan Geographical Areas of Particular Concern (GAPC) are noted.
Buffalo Harbor is located within the one-mile shoreline buffer zone as are the beach
and park areas listed in the comment. The impact on harbors is discussed in para-
graphs 4.062-4.069. The Bethlehem Steel Diked Disposal area is a proposed area
according to the CZM plan and is also within the one-mile buffer zone of the Refer-
ence Program. Seneca Shoals is the only GAPC within the boundaries of a potential
Reference Program leasing area. We agree that Seneca Shoals is a potentially sensi-
tive area. Should gas development be determined environmentally acceptable in
principle, the Corps will ensure that its permit review process provides special
consideration of any activities proposed in or near the shoal area, and no permit
would be issued if it is determined that there would be an unacceptable impact on
the public interest. The special consideration would include site-specific analysis
of impacts—including generation of necessary baseline data and coordination with
federal and state fish and wildlife resource agencies, the Coastal Zone Management
office, local agencies, and the general public. See Reponse EPA-1.
ENC-17 See Topical Response Number 9 on Water Supplies and Treatment Costs. The assessment
of whether or not an impact is significant is an essential part of impact analyses
as required by Council on Environmental Quality regulations for the National Envi-
ronmental Policy Act of 1969 (NEPA) and plays an important role in decision-making.
Determinations of significance are also used in judging the acceptability of various
impacts and in making decisions on issuance of permits. We do not agree that a
negative but insignificant impact is contrary to the protection and improvement of
water quality. Additionally, the acceptability of various discharges permitted
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Job B/LERES2/p. 5
under Sections 402 and 404 of the Clean Water Act include consideration of whether
or not an impact is significant.
ENC-18 See Topical Response Number 6 on Sediment Resuspension and Topical Response Number 9
on Water Supplies and Treatment Costs. Also, the impacts of gas development under
the Reference Program in regard to aquatic biota are discussed in paragraphs 4.028-
4.038 and 4.046-4.049. The results of the analysis indicate that the impacts would
be minor and localized and lakewide cumulative effects would be minimal. The state-
ment that gas development under the Reference Program has the potential to undermine
many if not all of the fishery improvements attained to date is unsupported by any
evidence or factual information.
ENC-19 See Topical Response Number 6 on Sediment Resuspension. It was indicated in para-
graph 4.059 that there would be some effect on recreation due to impacts to water
quality. These would be most evident during nearshore pipeline installation (turbi-
dity), and the impacts would be temporary and minor. Drilling activities would be
prohibited within one mile from shore, reducing the esthetic impact of resuspension
when viewed from the shore. Boaters could be subject to temporary esthetic effects
of discharges (paragraphs 4.148 and 4.149). Substantial degradation of water quality
to a point of adverse health hazards, prohibition of recreational use, and consump-
tion of fish (as indicated in this comment) is unsupported by the impact analyses in
the DEIS and this Final EIS.
ENC-20 See Topical Response Number 6 on Sediment Resuspension. Based on Reference Program
specifications, the bottom habitat disturbed by the jack-up rig pads is 1600 ft2
(paragraph 4.033). To the extent possible on a programmatic level, the impacts from
pipeline trenching and rig placement on water quality and aquatic biota are discussed
in Chapter Four of the DEIS. Testing of sediments at specific sites can only' be
accomplished when proposals have been submitted by operators.
ENC-21 Since the publication of the report by McGregor et al. (1978), additional studies
and analyses have been performed including'measurements of lakewide hydrocarbons
(Zapotosky and White 1980) and studies onboard an operating Canadian rig (Ferrante
et al. 1980). These studies included measurements of various discharges and ambient
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Job B/LERES2/p. 6
lake conditions. Additionally,- the projected impacts from specific discharges of
the Reference Program have been modeled since the publication of the report by
McGregor et al. (1978). The DEIS includes all additional analyses and information
since the latter report and is the document that addresses impacts of the Reference
Program. The conclusions reached in the DEIS do not indicate that the Reference
Program will degrade the chemical, physical, and biological integrity of the Lake,
but rather that impacts will be minor and localized. See also Response WEF-2.
ENC-22 The Reference Program is essentially a zero-discharge program with the exception of
the drilling of the primary surface hole by a floating rig and the release of that
portion of the stimulation returns that cannot be safely collected without the
threat of explosion (paragraph 1.097). All materials that can be feasibly collected
and brought to shore are so designated in the Reference Program. There are techno-
logical constraints in using closed-cycle during floating rig primary surface hole
drilling. All discharges that are permitted would be in accordance with regulations
promulgated under the Clean Water Act (e.g., Section 404 and 402 permits).
ENC-23 See Topical Response Number 12 on the Need for Natural Gas. Also, with regard to
manufacturing and the importance of this sector of the economy to the region, see
paragraphs 1.009, 1.018, and 3.125-3.137 of the DEIS.
ENC-24 To be supplied.
ENC-25 We analyzed wellhead prices but, as indicated in paragraph 4.186, Reference Program
prices are expected to be competitive with other sources of natural gas and would be
less than nonconventional sources, LNG, and Alaskan gas.
ENC-26 The DEIS discussed the present and
Lake Erie region (paragraphs 1.018,
also be aware that costs to develop
future importance of a gas resource to the
3.125-3.137, and 4.185). The commenter should
this resource will escalate in future years.
ENC-27
As indicated in Chapter Four of the DEIS, the impacts of the Reference Program on
shoreline esthetics, recreation, and sport fishing are expected to be minor. There
is no evidence that would support a conclusion of reduced attractiveness of the
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Job B/LERES2/p. 7
region to an extent that would have adverse effects on tourism, economics, popula-
tion trends, and employment. On the contrary, regional economic impacts are pro-
jected to be beneficial (see paragraphs 4.157, 4.175, and 4.180-4.187).
ENC-28 See Topical Response Number 9 on Water Supplies. The analysis of water quality
impacts and water supply impacts as contained in the DEIS and this Final EIS does
not support the conclusion that gas development would have a negative effect on the
region's image.
ENC-29 See Topical Response Number 11 on the Onland Alternative Program. Onland develop-
ment is occurring and is expected to continue (paragraph 2.063). The staff fails to
see any connection between the Reference Program and the longevity of existing
onland development or the depletion of onland gas resources. The Reference Program
one-mile buffer zone would prohibit significant extraction of gas from onland gas
reservoirs.
ENC-30 See Topical Response Number 10 on the Reference Program Concept and Topical Response
Number 11 on the Onland Alternative Program.
ENC-31 Statement noted. Our analysis indicates that the Task Force, Offshore Program
Office, and interagency cooperation would ensure that proper monitoring and enforce-
ment occur. Additionally, we project that only about eight operating rigs would be
needed for the Reference Program and the locations of the rigs would be known to
federal and state permitting agencies. This would also facilitate monitoring the
activities.
ENC-32 The Corps of Engineers (tinder its statutory authority and pursuant to its regula-
tions and permit conditions) and the states (under existing state law and regu-
lations) have adequate power to halt drilling; to limit number, size, and location
of drilling operations; and to regulate placement of landfalls and connected land
uses so as to harmonize with local interests. It is anticipated that claim settle-
ment procedures will be specified through two mechanisms: (1) as a component of the
required accident contingency plans, and (2) by incorporation into the terms of the
states' leasing programs, including the use of operator bonding to insure indemnifi-
cation of injured parties.
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Job B/LERES2/p. 8
It is not expected, overall, that there? will be significant effects on property
values. This projection, made at the programmatic level, may require revision when
actual facility siting is undertaken. Protection of property values from unreason-
able decline is provided by the need to comply with local land-use ordinances and,
in New York, with Article VII of the Public Service Law.
Provision of funds and detailing of procedures for reclamation of abandoned land
facilities would be accomplished primarily through incorporation of appropriate
terms into the states' lease contracts with the facility operators. Local laws may
require additional measures to meet the needs of local conditions.
Federal and state agencies, under existing law, have authority to monitor and to
require monitoring.
The leasing of any individual site will require approval by the Corps and the under-
taking of a site-specific EIS process. The Corps procedures incorporate public
interest review, and public participation is an integral part of the EIS process.
Public hearings and meetings held by the Corps and the commenting process provide
involvement of local authorities and citizens in the decision-making process.
ENC-33 The regulatory Task Force is envisaged as playing a crucial role in developing a
coherent iiiiplementation of an environmentally sound program for offshore natural gas
development in Lake Erie. It has the role of fusing political and technical con-
siderations into a unified whole. The commenter is correct to suggest the importance
of ensuring adequate representation of all interests involved in the development
process.
ENC-34 Restatement of previous comments noted.
ENC-35 See Topical Response Number 3 on the Task Force and Federal Regulatory Authority for
uniformity of programs. The extent of the Reference Program is a worst-case type
analysis and assumes maximum development under accelerated conditions. If actual
development deviates from the program it would more likely be of reduced scope.
Cumulative effects on a worst-case basis are accounted for by the fact that the DEIS
and this Final EIS are based on a maximum development scenario.
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Job B/LERES2/p. 9
ENC-36 Based on our analysis of Reference Program impacts, there is no evidence to support
the conclusion that the region would lose employment in the existing drilling
industry, recreation industry, or tourism industry.
ENC-37 The long-term vs. short-term effects of the program are discussed in para-
graphs 4.201 and 4.202. Unavoidable adverse impacts and irreversible and irretrievabl
commitments of' resources are presented in paragraphs 4.194 and 4.200. The con-
clusions reached after thorough impact analysis are not in agreement with the state-
ments made in this comment. See also Topical Response Number 8 on Glycol Chlorina-
tion and Topical Response Number 9 on Water Supplies and Treatment Costs.
ENC-38 There is no connection between an unsuccessful program and the establishment of a
precedent for unacceptable programs. If the program were unsuccessful in terms of
gas reserves, operator interest would most likely decline to a zero case. If it
were unsuccessful in terms of environmental impacts, as established during moni-
toring, permits could be suspended until the problem is resolved or if necessary
permits could be revoked in the public interest. The third case would be the
proposal by operators of technologies and methodologies that differ significantly
from the Reference Program. These technologies would have to be analyzed on a
case-by-case basis to determine the environmental acceptability of the proposals.
See Response EPA-1.
ENC-39 Statement of opinion noted.
ENC-40
Statement of position noted.
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Job C/LERES2/p. 1
MCH-1 Although release rates for petroliferous' lightweight hydrocarbon gases in Lake Erie
are unknown, locations and approximate concentrations have been determined in a
report by Zapotosky and White (1980).
The report of Zapotosky and White (1980) indicates the loss of petroliferous gases
into lake waters over gas fields in Canadian waters and over several areas in U.S.
waters. Releases into U.S. waters are probably from natural seeps originating in
Upper Devonian shales.
The toxicity of the major constituents of natural gas (i.e., lightweight hydro-
carbons) are relatively low. Concentrations over sites of natural gas release are
approximately 5-10 times lower than recommended Freshwater Aquatic Life Criteria
(Cleland and Kingsbury 1977). However, hydrogen sulfide, formation water, and
liquid hydrocarbons could also be introduced from releases. The potential impacts
of these inputs on water quality are addressed in Tables 4-4 and 4-5.
Hydrogen sulfide concentrations at the release point and 0.5 mile from the release
point could exceed the Freshwater Aquatic Life Criteria and the Drinking Water
Standards. Hydrogen sulfide is a constituent of natural gases derived from Lockport
reefs (Table 1-3; Figure 1-9). There was some indication of lower phytoplanktonic
metabolism over natural gas released from the Tilbury field (Zapotosky and White
1960). Hydrogen sulfide can be oxidized to sulfate during the water treatment
process.
Wells with the potential for producing greater than 5 gal/day of liquid hydrocarbons
upon initial formation test would be plugged and abandoned (Table 1-10). Although
the conditions for an oil blowout (e.g., geopressurized reservoirs, high liquid
carbon pore space saturation, high porosity and permeability) are not thought to
exist in the Reference Program Study Region, a Special Accident Category was
designed to hypothesize the effects of encountering an uncontrollable oil reservoir
while drilling into Ordovician or Cambrian rocks (Table 1-35).
MCH-2 The size of a gas resource is not the basis for determining its price to the end
user. The maximum wellhead price of natural gas produced in Lake Erie will be
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Job C/LEKES2/p. 2
regulated by the Natural Gas Policy Act until 1985. After 1985, market conditions
(supply and demand) will largely dictate natural gas prices." If the gas produced
from Lake Erie is used in the region, it may be cheaper than more distant sources of
supply due to lower transmission costs.
The final destination of Lake Erie produced gas cannot be determined at this time.
The gas could be used within, or out of, the Lake Erie region. Due to the economics
of natural gas transmission, however, it is likely that gas produced in Lake Erie
will be utilized in the region.
MCH-3 Restatement of information contained in the DEIS.
MCH-4 On an application-specific basis, the Corps would advise the city of Huron and the
general public of any proposals to drill in offshore Lake Erie, especially areas in
Ohio waters. The notification would be by public notice. Additionally, permit pro-
cessing procedures allow for public hearings on proposals. In regard to this pro-
grammatic study, the city of Huron will be advised of the decision that is ultimately
made concerning environmental acceptability of U.S. Lake Erie natural gas resource
development in principle. See Response EPA-1.
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Job D/LERES2/p. 1
MCB-1 Position on U.S. Lake Erie Gas resource development is noted. See Response MCB-4
concerning effects on revitalization. Also refer to Topical Response Number 6 on
Sediment Resuspension, Topical Response Number 8 on Glycol Chlorination, and Topical
Response Number 9 on Water Supplies and Treatment Costs.
MCB-2 It was noted in the DEIS that the potential for explosions exists if a pipeline rup-
tured or a gas leak occurred at a gas processing station. The analyses that were
performed were worst-case accident situations and, in assessing hazards, it is
necessary to consider the assumptions that were made. The explosion potential at a
gas treatment plant was designated in the DEIS as a "lowest frequency event." The
worst-case analyses assumed that all safety features would fail and also assumed
that certain events would occur in a set sequence. The gas processing plant acci-
dent assumed that a small nonroutine gas leak occurred followed by accumulation of
gas in the building and then a spark. This was assumed to create a snail explosion,
but that explosion was assumed to happen in a strategic location causing a valve or
high-pressure line to rupture, leading to an even greater explosion. As indicated
in the above discussion, many different events would have to occur in a certain
sequence to result in the worst-case accident. The worst-case analyses also assume
that there is no circumstance that prevents the accident. For example, proper
ventilation of the building could prevent the buildup of gas from a nonroutine leak.
Proper grounding of equipment and ensuring that there are no other sources of igni-
tion would prevent the worst-case accident. Safety maintenance and inspections
would reduce the chance of a leak, and leaks could be detected using gas detectors
strategically located in the building. Likewise, the break of an underwater pipe-
line assumed that ice or an anchor ruptured the line, all pressure-activated cutoff
valves failed, the atmospheric conditions allowed for buildup of an explosive gas
cloud, and an ignition source was nearby. Proper pipeline burial procedures, main-
tenance and inspection of safety valves, periodic testing of valves, and alarm
systems would all tend to minimize the potential for serious accidents. Finally,
any hazards associated with these types of facilities are not unique to the Reference
Program. There are numerous networks of gas pipelines buried throughout the region
and existing compressors are part of this regional network for gas distribution.
Refer to Topical Response Number 8 on Glycol Chlorination.
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Job D/LERES2/p. 2
MCB-3 In the DEIS, it was stated that the Po£t of Buffalo would probably be chosen by
operators as a work port and that the port would be able to absorb the peak vessel
traffic associated with gas development (paragraphs 4.058, 4.059, and 4.062-4.069).
Also, there would be temporary obstructions to navigation from the rigs and some
hazards to recreational boats. The analysis does not indicate any significant
effects on commercial navigation or recreational boating.
MCB-4 The U.S. Coast Guard and the U.S. Army Corps of Engineers have a responsibility to
maintain and protect shipping lanes and the movement of vessels into and out of
harbors. In addition, it should be emphasized that the drilling rigs will be tempo-
rary structures, wells are prohibited from the nearshore zone, pipelines will be
buried, and, while drilling is being conducted, rigs will be equipped with visual
and audible warning devices. These impacts are considered in paragraphs 4.062-4.069.
The DEIS also noted that beneficial economic impacts would accrue to a number of
Lake Erie ports if the natural gas resource were developed.
MCB-5 An Onland Alternative Program is discussed in Chapter Two. It should be emphasized,
however, that if the United States is to achieve energy independence, less energy
will have to be imported (thereby realizing substantial savings and strengthening
our economy) and more domestic sources will have to be developed. This includes all
sources of energy including onshore and offshore natural gas development.
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ECC-1 Statement of position noted
ECC-2 Comment noted.
Job E/LERES2/p. 1
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Job F/LERES2/p. 1
FDCA-1 In setting the review period for the D^IS, the Buffalo District Corps of Engineers
and the USEPA Great Lakes National Program Office allowed more than the 45-day
review period mandated by regulations to afford more time for review and account for
holiday periods. The notice of EIS filing as published in the Federal Register
advised of this voluntary extended review period. A public meeting was held in
Buffalo, New York, on 11 February 1981. See the public involvement section of this
Final EIS.
FDCA-2 Refer to Topical Response Number 8 on Glycol Chlorination and Topical Response
Number 9 on Water Supplies and Treatment Costs. Benefits would not be solely in
terms of financial gain to corporations. The benefits to the three states and to
the public in terms of jobs from the drilling itself as well as the regional economic
benefits accrued from a more secure gas supply are discussed in the DEIS (see para-
graphs 4.157-4.175 and 4.180-4.187).
FDCA-3 Terms such as the ones cited in this comment and others such as "expected, antici-
pated to be, predicted, etc." express the predictive nature of environmental impact
analyses. The reviewer should keep in mind the fact that this study is programmatic
in nature and that currently we do not have specific information on an actual
proposal and actual sites. The DEIS stresses the fact that site-specific and
proposal-specific information would be necessary for further refinement of impact
predictions.
FDCA-4 Although the short-term supply of natural gas appears favorable, most gas industry
analysts agree that the long-term prospects of adequate natural gas supplies are
uncertain.
FDCA-5 It is stated in paragraph 3.068 that the city of Buffalo has an emergency, secondary
intake located in an alternative water supply. The secondary intake is considered
to be in an alternative water supply in the DEIS due to the spatial separation of
the primary and secondary intakes. The primary intake identified in Table 3-3 is
considered to be the functional intake for the city of Buffalo and a constraint in
the Reference Program (Table 1-7).
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Job F/LERES2/p. 2
FDCA-6 In the DEIS, that it was stated that hydrogen sulfide would be oxidized by chlorina-
tion processes but the adding of additional chlorine was not indicated. See also
Topical Response Number 8 on Glycol Chlorination.
FDCA-7 See Topical Response Number 9 on Water Supplies and Treatment Costs. See Response
CCD-4.
FDCA-8 The availability problems of landfills and hazardous waste facilities were discussed
in the DEIS. On an application-specific basis, operators would be required to
provide a waste handling/treatment and disposal strategy as indicated in Appendix D,
paragraph D.020. A monitoring program for waste disposal areas is outlined in
paragraph D.025. See Response EPA-1.
FDCA-9 The paragraphs referred to (paragraphs S.018, S.019, and S.020) are summary state-
ments concerning impacts of accidents that are treated -in more detail in the main
body of the report. It must be borne in mind that, because of the large number of
variables involved, it is not possible to predict a specific accident or its conse-
quences precisely. The accident analysis does, however, indicate the likely magni-
tudes of the impacts of representative accident scenarios.
Statement of opinion noted.
FDCA-10 Assessment of site-specific impacts is beyond the scope of this programmatic DEIS.
Such impacts may be addressed in site-specific EIS's by permitting agencies. See
Topical Response Number 9 on Water Supplies and Treatment Costs.
FDCA-11 See Responses FDCA-10 and DOS-1.
FDCA-12 Statement of opinion noted.
FDCA-13 Statement of opinion noted.
FDCA-14 The Forest District is correct that no recommendation for monitoring cost pickup is
made. Usually, it is assumed the exploration company will pay. To recommend whether
the company or taxpayer should pay those costs is a normative recommendation in
wealth distribution theory and outside the scope of this EIS.
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Job G/LERES2/p. 1
EEC-1 Letters of comment on the DEIS were received from the Mayor of Buffalo (MCB) and the
Erie County Executive (CEXN). Refer to those letters and our responses to the
issues.
EEC-2 See Topical Response Number 1 on the Canadian Experience and Topical Response
Number 2 on Impacts of Accidents: Consideration of Canadian Experience.
EEC-3
See Topical Response Number 8 on Glycol Chlorination, Topical Response Number 9 on
Water Supplies and Treatment Costs, and Topical Response Number 12 on the Need for
Natural Gas.
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Job H/LERES2/p. 1
WEF-1 Position on U.S. Lake Erie gas developmfent is noted. See Topical Response Number 6
on Sediment Resuspension, Topical Response Number 8 on Glycol Chlorination, and
Topical Response Number 9 on Water Supplies and Treatment Costs.
WEF-2 Methane loading may contribute to the formation of anoxic conditions. In all known
situations, there is a narrow zone of maximal methane oxidation near the sediment-
water interface and a lower oxidation rate (10x) in the water column. Also, maximal
oxidation of methane occurs primarily at low oxygen concentration (<1 ppm). Welch
et al. (1980) think naturally produced methane is primarly oxidized at the sediment
water interface. There were no indications of oxygen depression at natural gas
input sites in unstratified areas or in the hypolimnion of the eastern basin of Lake
Erie (Zapotosky and White 1980). Production of anoxic conditions during periods of
ice cover are unreported and appear unlikely, based on reported oxygen concentra-
tions in the water column. In the central basin hypolimnion, natural gas inputs
were contiguous with biogenic methane inputs; therefore, the effects of each on
oxygen depletion could not be distinguished. Generally, maximum methane concentra-
tions from biogenic sources are 3 to 10 times greater than those associated with
natural gas releases (Zapotosky and White 1980).
The proposed action considered in the DEIS is the development of natural gas, not
gas and oil as in CLEAR Technical Report No. 132 (Michael and Herdendorf 1980).
See also Response MCH-1.
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Job I/LERES2/p. 1
ECS-1 Although the cited 1968 information may" have initially contributed to the ban on
U.S. Lake Erie gas development offshore of Pennsylvania, additional'proceedings by
the state resulted in the lifting of the ban in 1977 (see paragraph 1.002).
ECS-2 See Responses to the Erie County Health Department letter (CEH).
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TOH-1 Statement of resolutions noted
Job J/LERES2/p. 1
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Job K/LERES2/p. 1
GPU-1 The more definitive scheduled commercial operation date for the proposed Coho Station
is noted and falls within the range given in the DEIS. The Buffalo District is
cooperating with both the USEPA Region III Office and the GPU Corporation on the
review and analysis of the Coho Station. This will facilitate coordinated planning
between projects.
GPU-2 The conceptual design characteristics of the proposed cable as 1000 MW and about 250
to 325 kV is noted. Although it differs slightly from the earlier information
available to us when scoping the DEIS, this would not affect the conclusions reached
in the DEIS. The scheduled operation date is noted and is within the range given in
the DEIS. The Buffalo District is a cooperating agency with the Department of
Energy on preparation of an EIS for the Lake Erie Interconnect Cable.
GPU-3 Comment noted.
GPU-4 As indicated in paragraph 4.193, lease sales will have to be designed to keep gas
development activities away from the planned underwater cable. Additionally, the
Corps would be required to process permit applications for various gas development
activities such as drilling, wellheads, pipelines, etc. The public interest review
performed by the Corps would include consideration of existing and planned utility
lines in the Lake. The review process includes notification by public notice to the
owner/operator of utility lines in the project area. Rather than set a buffer zone
at this time, we believe that specific information concerning gas development sites
and proposed procedures and specifications about utility line locations, installa-
tion, maintenance, and operation would lead to better definition of potential prob-
lems and necessary measures to avoid or mitigate these problems. It would also be
necessary to know the procedures proposed by gas development operators in regard to
pipeline and wellhead installation and maintenance. The recommendation of 300 meters
a
on each side of the proposed cable is noted. However, we believe that site-specific
determinations would lead to more the accurate determinations necessary for protec-
tion of each utility line in the Lake.
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Job L/LERES2/p. 1
DTED-1 Refer to Topical Response Number 1 on the Canadian Experience. We have reviewed the
enclosure cited in the comment and find that it provides information on the history
of the Canadian Lake Erie program and various recommendations that were made by the
International Joint Commission (IJC). The text of the enclosure is very similar to
both the information contained in our Phase 1 report (McGregor et al. 1978) and the
discussion contained in the DEIS relative to IJC recommendations. The enclosure
contains no information concerning measured impacts of gas development in the Lake
or any information that would change the conclusions reached in the DEIS.
DTED-2 The Reference Program prohibition on oil development in Lake Erie is based on the
recommendations made by the IJC, as discussed in paragraphs 1.002 and 1.022. Also,
we are analyzing the impacts of gas development in Lake Erie on the federal level
because of renewed interest in such development by the states of New York, Pennsyl-
vania, and Ohio. The level of interest expressed in regard to natural gas develop-
ment has not been expressed for oil development.
We appreciate your cooperation in our effort to recycle copies of the document.
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Job M/LERES2/p. 1
RC-1 It is the responsibility of a professional to make evaluations and judgments on the
basis of the best information available. Where better information is not available,
evaluation and judgment must be made on the basis of what information is available.
In preparing this document, every effort was made to use the best information avail-
able, to clearly indicate the reliability of sources of information used, and to
identify the sources with the degree of particularity appropriate to their relia-
bility.
The citation in this comment from page 1-20 of the DEIS is taken out of context.
The DEIS did not state that this was the only source of information, but rather that
much of the information was from government record, published reports, and Canadian
government reports.
RC-2 The staff agrees with the comment that it is difficult to address the cost borne by
applicants (drilling operators) during the permit process. Total investment cost to
develop the 16 lease areas of the development program and the resultant net current
values are estimated to range between $28 million to $650 million and $41 million to
$850 million, respectively. Even the cost associated with worst-case scenario of
obtaining permits would not alter the economic decision to develop U.S. Lake Erie
gas.
Also, this comment assumes that all future actions will constitute a Major Federal
Action Significantly Affecting the Quality of the Human Environment and thus require
the preparation of an EIS. The Corps has not made such a predetermination. Refer
to the EPA letter (EPA) of comment and the Chautauqua County Deptartment of Planning
and Development letter (CCD) concerning EIS requirements. Comparisons of state
hearing procedures to those that are contained in the Corps permit program are
inappropriate. The Corps hearings are not lengthy processes and are not adversary
type hearings with cross-examination of witnesses. The cost to applicants for Corps
public hearings is minimal.
RC-3 In paragraph 2.035, it was pointed out that "at present, there are no commercial
wells producing gas from geopressured aquifers and only two experimental attempts
have been made." Gas production from this source will be in the distant future. .
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Job M/LERES2/p. 2
The most likely alternatives for near-term gas supplies are summarized in para-
graphs 2.044-2.046. An important point, however, is that in order to meet future
energy needs in the United States, all domestic sources of energy will have to be
utilized including offshore natural gas development. See Topical Response Number 12
on the Need for Natural Gas.
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Job N/LEKES2/P- 1
GLL-1 The potential supply of natural gas fr'om other sources and its availability to
end-users within the near term was addressed in the DEIS. All alternative sources
of energy supply (e.g., solar, geothermal, nuclear) were not addressed; such
discussion is beyond the mandate of this DEIS.
GLL-2 Although the Lake Erie region did not experience natural gas shortages and curtail-
ments during the past two winters, there is no reason to believe that a repetition
of events which occurred during the winters of 1976-1977 and 1977-1978 will not be
repeated. The Federal Energy Regulatory Commission system of curtailments is based
upon a priority system with industrial end-users among the first to be curtailed.
This system is still in effect and will be imposed upon end-users in the event of
future natural gas shortages.
GLL-3 The ultimate distribution of any natural gas produced in Lake Erie cannot be deter-
mined at this time. There are several distribution alternatives. For example, the
gas could be developed and used by the producer on a self-help basis; the gas could
be sold to regional natural gas utilities (East Ohio Gas, for example) for local
distribution; or the gas could be developed by a major producer-transmission company
and piped out of the region for consumption in other parts of the country. Due to
the economics of gas distribution and the demand for gas in the Lake Erie region, it
is likely that the gas would be developed by a major producer-transmission company
(Consolidated Natural Gas Company, for example) and sold to local utilities to be
utilized within the heavily industrialized Lake Erie region.
GLL-4 The fire aboard the jack-up drilling rig Mr. Neil was caused by leakage of oil from
a ruptured hydraulic line during jacking of the rig. The oil contacted a hot engine
and ignited. A 25-mph wind hampered attempts to extinguish the flames, and the fire
burned for approximately 3.5 hours. The fire destroyed the mud pump and damaged
on-rig enclosures including the recreation house, wheel house, tool-pusher's house,
and logging house. Damage to the rig structure was minimal. After the fire was
extinguished, the rig was jacked down, towed to port, repaired, and returned to
service in six weeks. The on-rig inventory of drilling supplies was not lost, and
the environmental consequences of this accident were minor. A broad range of acci-
dent classes, including some much more severe than the Mr. Neil fire are treated in
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Job N/LERES2/p. 2
the DEIS. These scenarios include capsizing of the rig with loss of the entire
inventory of materials aboard and loss of well control, the worst likely results of
a rig fire. The consequences of these scenarios may be used to estimate the worst-
case effects of an on-rig fire or explosion.
GLL-5 In the Reference Program, drilling is prohibited and pipeline corridors are excluded
within 0.5 mile of a potable water intake.
The potential source of polyethylene glycol is a broken glycol feeder line. If a
glycol line is broken without a break in the gas line or if it is broken suffi-
ciently far from the gas-line break that turbulence induced by escaping gas is
insufficient to increase the rate of mixing of polyethylene glycol with water, the
higher density of the glycol (relative to that of water) will tend to keep it near
the lake bottom, thus isolating it from mid-depth regions where water intakes would
be located. Since near-bottom current speeds are smaller than those higher in the
water column, this also restricts the speed of down-current transport.
In the event that glycol is transported upward by currents induced by gas rising
from a pipe break, the flow is expected to be highly turbulent, causing rapid mixing
of glycol and lake water and thus eliminating the density difference. The current
speed used in estimating down-current glycol concentrations was 55 cm/s, well above
speeds expected at mid-depth.
GLL-6 See Response CEXN-6.
GLL-7 It is stated in paragraph 3.068 that the city of Buffalo has an emergency, secondary
intake located in an alternative water supply. The secondary intake is considered
to be in an alternative water supply in the DEIS due to the spatial separation of
the primary and secondary intakes. The primary intake identified in Table 3-3 is
considered to be the functional intake for the city of Buffalo and a constraint in
the Reference Program (Table 1-7). Reference Program activity impacts that would
require the use of alternative water supplies, including accident impacts, are not
identified.
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Job N/LERES2/p. 3
GIX-8 Some of the data on seismicity were taken from the Lawlec, Matusky & Skelly Engi-
neers (1977) report' as cited, but additional information and data from a number of
other sources pertinent to regional seismicity (cited in the DEIS) were also
analyzed and assimilated in the preparation of paragraphs 1.053 through 1.056.
GLL-9 Information on the costs of cleanup are addressed in paragraphs 1.081 and 1.0S3.
Financial support for regulatory (and monitoring) activities will probably originate
from operator payments to the states (paragraph 1.068). The need for alternate
water supplies due to releases from routine operations or accidents is not antici-
pated (paragraphs 4.071-4.073). See Topical Response Number 9 on Water Supplies and
Treatment Costs.
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Job 0/LEKES2/p. 1
MNF-1 See Response DOI-17. The staff acknowle'dges that an error was made; however, it had
no bearing on the impact analysis since the analysis assumed protection of commer-
cial fisheries in all three states.
MNF-2 The potential effects on commercial fisheries from gas development activities and
suggested mitigation for the Reference Program are derived from the Canadian experi-
ences in the Lake (see paragraph 3.056). We concur with your statement that such
problems can be resolved and the Buffalo District will ensure that Minor Fisheries
is advised of the results of this programmatic study. If development is ultimately
found acceptable in principle, we would advise you of any specific proposals received
by this office.
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Job P/LERES2/p. 1
UFF-1 Position on U.S. Lake Erie gas development is noted. See Topical Response Number 12
on the Need for Natural Gas. Also, on page 6 (Table IV-1) of the American Gas
Association (AGA) 1980 report, a decline in lower-48-state production from 16-18 Tcf
to 12-14 Tcf in 2000 is shown. The loss must be supplemented by other sources such
as imports, Alaskan gas, LNG, and nonconventional sources. This is premised on the
gas industry maintaining a 26% share of total energy, and any worsening of the
petroleum situation could shift the gas share higher. On page 13 of the AGA report,
the statement is made that "it is clear that conventional gas supplies will not be
adequate." On the same page, the statement is made that "with increasingly pessi-
mistic oil supply picture, the nuclear hazard uncertainties, and the woes of direct
coal use, it makes sense to plan supplies conservatively, to shoot for the full
potential range of supplemental gas supplies while attempting to boost conventional
production at the same time." Although the 1980 AGA report may present an optimistic
outlook for gas, the tone of the report is very cautiously optimistic and advises of
uncertainties in forecasts.
UFF-2 See Topical Response Number 8 on Glycol Chlorination and Topical Response Number 9
on Water Supplies and Treatment Costs.
UFF-3 See Topical Reponse Number 5 on the Great lakes Water Quality Agreement of 1978; the
1909 Boundary Waters Treaty between the U.S. and Canada; and the International Joint
Commission.
UIT-4 Information on the seismic activity of the Reference Program region is presented in
paragraphs 1.053-1.056. The conclusion reached is that the intensity of earthquakes
expected for the region is not anticipated to have significant, if any, effect on
offshore operations. The presence of facilities mentioned in this comment would
have no effect on any earthquake intensity and thus no effect on structures asso-
ciated with gas development.
UFF-5 See Topical Response Number 1 on the Canadian Experience.
UFF-6 See Topical Response Number 7 on Contingency Plans and Cleanups, Topical Response
Number 8 on Glycol Chlorination, and Topical Response Number 9 on Water Supplies and
Treatment Costs.
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Job P/LERES2/p. 2
UFF-7 See Topical Response Number 6 on Sediment Resuspension.
Fire prevention equipment on vessels (rigs, tugs, barges, etc.) operating in U.S.
Lake Erie waters would have to comply with offshore regulations, which should be
adequate for Lake Erie natural gas development.
Very little production equipment exists under water, and it is doubtful it will need
reservicing during the life of the wells.
UFF-8 Statement noted.
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Job Q/LERES2/p. 1
JH-1 Position on U.S. Lake Erie natural gas resource development is noted.
JH-2 The Reference Program drilling seasons are designed to reflect the dates that the
Lake is clear of ice; therefore rigs would not be operating in ice cover (see
Table 1-7 and paragraphs 1.049 and 1.050).
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Job R/LERES2/p. 1
CSS-1 The industrial use of natural gas was emphasized in the DEIS. A primary reason for
this was that during the 1976-1977 natural gas shortage, industrial gas users in the
Lake Erie region experienced curtailments, whereas the residential sector did not.
CSS-2 Industrial natural gas shortages to the Lake Erie region during the winters of
1976-1977 and 1977-1978 created severe economic hardships to numerous industries and
their employees. Although a number of newspapers in the region carried daily
accounts of "plant closings and employee layoffs", no comprehensive economic
analysis of this crisis could be located.
Based on comments from the Federal Energy Regulatory Commission (FERC), the long-
term effects of the Natural Gas Policy Act cannot currently be predicted. Thus,
although information on the economic impact of the 1976-1977 shortage may be illus-
trative, it is not necessarily predictive.
CSS-3 The Reference Program is being used to determine if gas development can be accom-
plished in an environmentally acceptable manner in principle¦ If the program is
ultimately judged acceptable, it could be used as a guideline or reference point for
the review of specific proposals. In the footnote at the bottom of page 1-7, it is
noted that future program proposals could vary significantly from the Reference
Program, could constitute relaxed technological standards, and could be evaluated on
a case-by-case basis to determine the consequence of allowing increasing amounts of
materials and residuals to enter the environment. However, if the Reference Program,
which limits discharges to the smallest possible amounts, cannot pass the test of
environmental acceptability, then in principle U.S. Lake Erie natural gas develop-
ment must be rejected. This rejection includes consideration of the sensitive uses
of Lake Erie water and the current economic and energy situation in the region. The
DEIS discussed the economic and energy benefits in paragraphs 1.017-1.019,
1.150-1.162, 3.125-3.136, 4.157-4.175, and 4.180-4.187. For the purpose of the
programmatic DEIS, the current political climate is taken to be the interest by the
states in U.S. Lake Erie gas development. We agree there are certain atmospheric
benefits when comparing the combustion of gas vs. coal and oil, particularly in
terms of sulfur dioxide. However, we would also point out that the Powerplant and
Industrial Fuel Use Act of 1978 reemphasizes the need for the United States to
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Job R/LERES2/p. 2
switch from oil and gas to more plentiful domestic hydrocarbon fuels such as coal
(in terns of industrial use).
CSS-4 See Response EPA-11.
CSS-5 See Response CSS-8.
CSS-6 See Topical Response Number 1 on the Canadian Experience. A brief description of
the Canadian operations is contained in the McGregor et al. (1978) report.
CSS-7 Although the role of FERC is discussed in paragraphs 1.014 and 2.007, we agree that
further delineation of the Commissions' role is desirable and have included an
errata to the DEIS. See new paragraph 1.015a in the errata section of this Final
EIS. The limits of any site-specific EIS that may be required can only be defined
after consideration of the particular proposals and the proposed work sites. For
example, if work were proposed in areas that are suspected of having contaminated
sediment or in areas of important fish spawning, the EIS would be scoped differently
than for a proposal that had very little potential to stir and release contaminated
sediment or adversely affect fish populations. During the scoping process for an
EIS, the Buffalo District does include the involvement of other agencies (state,
federal, and local) and the general public, and one of the purposes of scoping is to
ensure that limits of the analysis are clearly defined. Scoping also reduces dupli-
cation of efforts by involved agencies. Refer also to Response EPA-1 concerning EIS
preparation.
CSS-8 The response to all of these comments requires a brief discussion of the revised
Resource Conservation and Recovery Act (RCRA) regulations promulgated May 19, 1980
(45 FR 33066 et seq.). The special waste category has indeed been eliminated, but
contrary to the contention of Columbia Gas, drilling muds are not exempt from the
provisions of RCRA. It is true that the revised regulations in 40 CFR 261.4(b)(5)
exclude drilling fluids, produced waters, and other wastes associated with the
exploration, development, or production of natural gas from the hazardous waste
category of RCRA. Such wastes are thus not subject to the Subtitle C regulations
for Hazardous Haste Management, e.g., "cradle-to-grave" monitoring. This exclusion
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Job R/LERES2/p. 3
was prompted by congressional amendments to RCRA which (as described in the May 18,
1974, Environment Reporter) provide for a study of these wastes in order to ascertain
their degree of hazard, if any [see also 40 CFR 26 (III)(E) in 45 FR 33089)]. Even
if on completion of this study, these wastes are deemed to be nonhazardous in the
RCRA sense, they are still subject to regulation under Subtitle D of RCRA, which
provides for criteria for environmentally acceptable disposal facilities, Also note
that monitoring or regulation of any toxic additives is suggested in paragraph 1.116
as part of the Reference Program. Additionally, see Comment EPA-3.
CSS-9 See Response CSS-8.
CSS-10 See Response CSS-8.
CSS-11 See Response CSS-8.
CSS-12 In paragraph 2.088, it is stated that pipelines could be buried (small streams) or
suspended (rivers). We did not intend to imply that aerial crossings were common
but that they are an option which is available.
CSS-13 A conversion table was provided in the DEIS.
CSS-14 There was no existing information on Lake Erie hydrocarbon levels and we needed an
indication of existing levels to determine possible impacts on the existing environ-
ment. The study will also serve a purpose in the future if gas development in U.S.
Lake Erie eventually occurs. The report was distributed to various public libraries
along the Lake Erie coast and is available from the National Technical Information
Service of the U.S. Department of Commerce. It is also available for review at the
Buffalo District office.
CSS-15 Typographical error is acknowledged. The correct word is "panfish".
CSS-16 See Response DOI-17. Only a long-term detailed study including historical accounts
of the fishery during gas development activities in Canada could provide any meaning-
ful indication of the effects on productivity in Canada. Natural fluctuation in
populations would also have to be considered.
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Job R/LERES2/p. 4
CSS-17 In general study of the demand for natural gas, the cross-price elasticity of demand
is found to be positive with respect to other fuels—if the price of substitute
fuels (e.g., #2 oil or #6 oil, etc.) increases faster than the price of natural gas,
more natural gas will be demanded. Currently, because the price of fuel oil is
rising faster than the price of natural gas (on a Btu basis), one would expect the
quantity of gas demanded to increase.
Paragraph 3.130 refers to an almost zero cross-price elasticity of demand in the
short run. As such, there would be no substitution of natural gas for other fuels
in the short run—gas would continue to be demanded for its primary use in the
manufacturing process or as a feedstock.
CSS-18 We agree that there are numerous sources of information including documents prepared
by FERC, the American Gas Association, and the source used in cited Table 3-13.
However, Table 3-13 was included only for the purpose of demonstrating that there
are major industrial groups in the region that are gas-intensive, that they are
sensitive to curtailments, and that the state of Ohio consumed more natural gas than
New York and Pennsylvania combined (within the Reference Program study area). The
McGraw-Hill (1978) reference serves the purpose for which it was intended.
CSS-19 See Response MCH-1.
CSS-20 The "reef-effect" referred to in the cited article occurs at permanent structures
where sufficient time passes to allow colonization of the structures by organisms.
The Reference Program drilling would involve only temporary residence times for a
rig in any drilling location.
CSS-21 The DEIS discussed in some detail the" importance of natural gas to the Lake Erie
regional economy and in particular to the industrial sector (paragraph 1.009, 1.018,
3.125-3.137, 4.185, and 4.201). The development of a Lake Erie gas resource could
help the regional economy. Projections relating to socioeconomic impacts are
discussed in paragraphs 4.154-4.175. It is impossible to determine at this time
whether operators would buy steel or other material locally or nationally. Due to
the transportation costs of steel and steel products, however, it is reasonable to
assume that most production material would be obtained within the region.
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Job R/LERES2/p. 5
CSS-22 An analysis of U.S. dependence on foreign oil and the U.S. balance of payments is
beyond the mandate of this DEIS.
CSS-23 Natural gas liquids consist mainly of the light hydrocarbons (propanes, butanes).
These liquids are highly volatile and will vaporize readily under atmospheric condi-
tions. However, these liquids are in a liquid state under production conditions of
much higher pressures, and they would enter the Lake as liquid if a line should
break while the well was producing. As a liquid, these hydrocarbons may be somewhat
soluble in water and, therefore, cause environmental problems when some of the
liquid goes into solution as it migrates to the surface of the Lake. Statement of
position noted.
CSS-24 See Response CSS-8. Because a particular waste is determined nonhazardous under the
Resource Conservation and Recovery Act does not imply that the waste is suitable for
discharge into a waterway. For example, phosphorus may not be toxic or hazardous,.
but the limitation of phosphorus for reasons other than toxicity has been identified
as an objective for Lake Erie in the 1978 Water Quality Agreement.
CSS-25 See Topical Response Number 10 on the Reference Program.
CSS-26 Plugging of wells at 5 gallons/day (paragraph D.035) is arbitrarily set for the
Reference Program as an indication of significant liquid hydrocarbon production.
This should not be interpreted as a recommended upper limit, and in the DEIS it is
assumed that an actual leasing program would evolve its own limits via standards set
by the states and federal water quality agencies (paragraph 1.039). Some regula-
tions bearing on the issue are in place or have been proposed (Table 1-10 and
Table A.l, Item 30). See Topical Response Number 10 on the Reference Program Concept.
CSS-27 The following definition was taken from Amyx et al. (1960—p. 225, paragraph 3):
"Hydrocarbon mixtures which exist in the liquid state at reservoir conditions are
commonly classified as crude oils and subdivided on the basis of liquid yield into
low- and high-shrinkage oils." This definition may or may not cover condensate, a
term which is misleading at times. Much of the petroleum industry attaches the term
'condensate' to any high-gravity (above A0° API, for example) liquid hydrocarbon
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Job R/LERES2/p. 6
produced from a well. Actually, condensate is the liquid produced when a rich gas
(high-Btu content) is brought to separator conditions from reservoir conditions.
However, this condensate is still a hydrocarbon mixture existing in a liquid state
at surface conditions, the same as any crude oil.
The DEIS is concerned strictly with the production of an excess amount of hydro-
carbons existing in a liquid state at surface conditions (wellhead, separator,
etc.). Once 'condensate' becomes a liquid, it can be classified with crude oil as a
"liquid hydrocarbon", and it becomes subject to the restrictions set forth in the
DEIS for liquid hydrocarbons. Therefore, it is not necessary to either distinguish
between or redefine either of these liquids because both are treated with the same
set of restrictions.
CSS-28 As indicated in Appendix D and the section of Chapter One that outlines the regula-
tory and administrative procedures, the basis for the Reference Program guidelines
is contained in the cited Acts. However, the regulations promulgated under the Acts
are not necessarily specific to a particular proposal or site. The prohibitions in
the DEIS are not arbitrary but are based on the results of the programmatic environ-
mental impact analysis contained in the DEIS and are intended to provide protection
from accidents, protection of drinking water and groundwater supplies, and generally
ensure the protection of the environment.
CSS-29 A decision concerning the environmental acceptability of U.S. Lake Erie gas develop-
ment in principle will not be made until after the Final EIS has been filed with
USEPA headquarters and the mandatory 30-day administrative waiting period has expired.
CSS-30 See Topical Response Number 1 on the Canadian Experience.
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Job S/LERES2/p. 1
LWVO-1 Statement noted. The long-term energy Strategies and policies and interim policies
are essentially established by the President and Congress in the form of public
laws, policy statements, and executive orders which authorize and/or direct various
federal agencies to promulgate appropriate regulations. Some of the current Acts
which relate to long-term strategy are discussed in paragraphs 1.010 to 1.015 of the
DEIS. These policies essentially call for conservation efforts, fuel switching,
greater reliance on more abundant fuels, and reduction of imports during the transi-
tion period from current energy sources to future sources. Most of the studies that
have been performed in recent years indicate that a transition period into the early
2000s is needed to replace current sources with many of those energy sources indi-
cated in this comment.
LWVO-2 See Topical Response Number 6 on Sediment Resuspension, Topical Response Number 8 on
Glycol Chlorination, and Topical Response Number 9 on Water Supplies and Treatment
Costs. Development of oil in Lake Erie is prohibited under the Reference Program.
A worst-case accident analysis of oil blowout is contained in the DEIS because of
the perceived public concern but not because of its likelihood of occurring. See
also Topical Response Number 7 on Contingency Plans and Cleanups.
LWVO-3 Statements noted. See Topical Response Number 9 on Water Supplies and Treatment
Costs.
LWVO-4 See Topical Response Number 7 on Contingency Plans and Cleanups, Topical Response
Number 8 on Glycol Chlorination, and Topical Response Number 9 on Water Supplies and
Treatment Costs.
LWVO-5 See Response DOS-1 and HHS-3. The seismicity of the Lake Erie region is thoroughly
discussed in the DEIS. Portions of the lake basin are located in seismically active
areas as described in paragraphs 1.053-1.056.
LWVO-6 The CLEAR report by Michael and Herdendorf (1980) was reviewed by the USEPA, Corps,
and Argonne National Laboratory. However, citing the report as a reference would
not result in new information concerning impacts or new conclusions with regard to
the DEIS. The report discussed potential impacts of sediment resuspension, salt
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Job S/LEKES2/p. 2
loading, methane, and oil. Although did not utilize the report as a reference,
we did analyze the potential effects of these same pollutants but related the poten-
tial to the Reference Program itself. In other words, although the CLEAR report
points out possible effects of these substances, it was published prior to the DEIS
and could not account for either the technologies used in the Reference Program to
avoid or minimize potential inputs or the guidelines and prohibitions applicable to
the Reference Program. The references we utilized—including the reports by McGregor
et al. (1978), Zapotosky and White (1980), Ferrante et al. (1980), and others—
provided the necessary information to analyze the impacts from the Reference Program
in regard to methane loading, salts, oils, and sediment. See also Response WEF-2.
LWVO-7 The commenter is correct in noting that both the federal regulations dealing with
hazardous waste disposal (such as those promulgated under the Resource Conservation
and Recovery Act) and the corresponding state regulations are to some extent still
in a state of flux, but the waste management strategy presented as part of the
Reference Program is likely to be compatible with the final forms of such regula-
tions at either the federal or state level. The issuance of site-specific drilling
permits must be contingent upon the availability of suitable waste disposal sites.
As correctly noted in the comment, adequate financial support, trained personnel,
and coordination with the Safe Drinking Water Act and other programs must also be
prerequisities to the issuance of site-specific drilling permits.
LWVO-8 Currently, the Commonwealth of Pennsylvania is the only state in the Reference
Program area that has a Coastal Zone Management (CZM) plan that has been approved
under the Coastal Zone Management Act. Although there are no provisions in the Act
that require approval of a state plan by the U.S. Department of Commerce prior to
issuance of federal permits, the Corps of Engineers does coordinate its permit
program with the states and considers the impact of permit issuance on the coastal
area. Thus, a state has the option of objecting to issuance of a federal permit on
the grounds of unacceptable impact to their coastal area even if the CZM plan has
not yet been approved. If the state also has a permit program covering activities
in waters of coastal areas, it may also deny its permit authorization. Additionally,
the Corps of Engineers public interest review during permit application processing
includes consideration of erosion, fish and wildlife, water quality, water supplies,
recreation, wetlands, and other factors.
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Job S/LERES2/p. 3
LWVO-9 See Topical Response Number 7 on Contingency Plans and Cleanups and Topical Response
Number 9 on Water Supplies and Treatment Costs. Monies from royalties, etc., are
pertinent to the states since they own the mineral rights.
LWV0-10 See Topical Response Number 12 on the Need for Natural Gas. The Federal Energy
Regulatory Commission cannot at the present time predict the effects of the Natural
Gas Policy Act in the long term.
LWVO-11 Comment noted.
LWVO-12 The role of energy conservation in the total energy scene is acknowledged as impor-
tant, and the end result of vigorous conservation will be primarily the benefits in
terms of release of pollutants to the environment. However, the actual achievement
of significant total energy savings through vigorous conservation effort is highly
sensitive to factors such as international politics; inflation; government energy
programs on the federal, state, and local levels; supplies and prices of all energy
sources; population growth; consumer habits; and many other factors that are highly
unpredictable. The total energy savings would then have to be related to the natural
gas situation. The analysis in the DEIS was therefore directed to conservation as
it pertains to the natural gas situation. As indicated in paragraph 2.061, natural
gas demand in the region has already demonstrated the effects of conservation and,
in the short term, conservation will continue to reduce demand. The long-term
situation is less clear. Although the cited source, Energy Future, presents an
optimistic outlook, other major energy studies are not as optimistic. The report
Energy in Transition prepared by the National Research Council (1979) advises that
conservation alone will not bridge the energy demand-supply gap foreseen for
1985-2010. The report further indicates that solar/renewable sources outside of
hydroelectric are not likely to contribute more than 5% by 2010. Another study of
the worldwide situation (Int. Inst. Appl. Systems Analysis 1981) is optimistic
about the future energy scene but also advises that if solar energy is to become a
competitor, it will have to capture at least 1% of the world market by the end of
the century and 7% by 2030. The worldwide report concludes that the entire study
period 1980 to 2030 will be dominated by fossil fuels, and coal will be in the
greatest supply.
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Job S/LERES2/p. 4
LWVO-13 Self-help gas has been successful in the state of Ohio, but as indicated in para-
graph 2.010, it is extremely costly to many companies that cannot financially assume
the costs and it is not a short-term or long-term solution to regional gas demands.
See Topical Response Number 11 on the Onland Alternative Program. In regard to
comparisons of onland development problems with the Reference Program, the Reference
Program is specifically designed to ensure that proper techniques, restrictions,
disposal methods, and inspections are incorporated. Additionally, Corps permit
programs require that applicants provide the necessary information on activity
location that will assist in monitoring and enforcing program requirements. Another
important factor is that we do not project a high number of operating rigs (about
eight), and this would also facilitate monitoring.
LWVO-14 Refer to Response LWVO-12 concerning solar energy. For the purposes of the regional
situation in the Reference Program, the potential and possible drawbacks of coal
gasification and coal seam methane are included in the DEIS to the degree necessary
for a reasoned comparison of alternatives.
LWVO-15 The maximum wellhead price of natural gas produced from Lake Erie will be regulated
by the Natural Gas Policy Act (NGPA) until 1985. After 1985, market conditions
(supply and demand) will largely dictate natural gas prices. In addition to the
wellhead price, its costs to end-users will reflect transmission and other costs.
If the gas is utilized in the Lake Erie region, transmission costs would be less as
compared to gas delivered from Louisiana. The price of Lake Erie gas to end-users
will probably reflect a "rolled in" price. That is, end-users will pay a weighted
average price reflecting both high- and low-priced natural gas sources. Thus, in
terms of an "energy costs—competitive disadvantage" to industrial end-users, Lake
Erie gas will probably be another source of gas whose final price is an "average
price." This price could possibly be somewhat lower than other sources, reflecting
lower transmission costs; but it may also be somewhat higher, reflecting a higher
cost of offshore production.
LWVO-16 Producers will not develop any Lake Erie gas unless it is economically feasible to
do so. This means that the cost of production and the wellhead price of the gas
must enable the producer to make a reasonable rate of return on his investment.
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Job S/LERES2/p. 5
The ultimate designation of the gas—i.e., whether it will be produced on a self-
help basis by a large industrial natural gas user or by a petroleum gas company and
sold to local utilities—cannot be determined at this time. The importance of
natural gas to many industries in the Lake Erie region is discussed in the DEIS
(paragraph 1.018, 3.130-3.137, and 4.185).
LWVO-17 The Ohio League of Women Voters is correct that a full analysis of benefit and harm
should take into account social costs not explicitly balanced against revenue in
this DEIS (pages 108 to 113). However, without a full risk analysis, which is
beyond the scope of this DEIS, such costs are difficult to estimate as well as being
subject to considerable disagreement. Essentially, this DEIS assumed such costs to
be small (pages 1-113 and 1.162, last paragraph). The extent of the financial
analysis was limited to a determination of whether such a program would be profitable
for industry operators (paragraph S.006), and not whether the net social dollar
value was positive or negative for all concerned.
It is possible that the regulatory Task Force would develop its recommended minimum
standards to be implemented through federal and state regulations. In the course of
developing such standards the Task Force, consistent with Executive Order 12291,
would assess the costs and benefits of implementing the standards and identify where
the costs and benefits would fall.
Additionally, see Topical Response Number 7 on Contingency Plans and Cleanups.
LWV0-18 Summary of specific comments above noted.
LWV0-19 This Final EIS provides the requested summary of public views, comments, and
concerns and the responses to these comments.
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Job T/LERES2/p. 1
NAS-1 Spill prevention measures are mandated by various existing federal and state statutes
and regulations (see Appendix D). The Task Force may recommend new measures appro-
priate to the special environment of Lake Erie offshore drilling. Detailed discus-
sion of site-specific measures would be contained in any EIS associated with a
specific permit application. See Topical Response Number 7 on Contingency Plans and
Cleanups.
NAS-2 See Topical Response Number 6 on Sediment Resuspension.
NAS-3 The statement made in paragraph E.008 concerning the altering of lake ecosystems
from acid precipitation related primarily to certain lakes in the northeastern
United States that are particularly sensitive to acid rain because of the inability
of these lakes and soils surrounding these lakes to buffer the acidic conditions.
The extent of change in acidity of a lake or stream is determined primarily by the
capacity of the surrounding soil to buffer and by the composition and size of the
watershed in which the water resides, lake Erie is a lake unlike those mentioned in
Appendix E and, as discussed in paragraph 3.065, Lake Erie is highly buffered. In
regard to Lake Erie gas development, changes in the acidity of the Lake from the
drilling and production phases are not expected.
For further information on acid rain effects in general, we refer you to the USEPA
(1980) document entitled "Acid Rain."
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Job U/LERES2/p. 1
LEBC-1 Statement noted. No response required.
LEBC-2 The importance of Lake Erie as a water supply to the region and the potential impacts
to the potable water supplies from potential gas development activities are dis-
cussed in the DEIS. Also considered is the use of groundwater in the region and the
potential environmental impact on groundwater from gas development activities. See
Topical Response Number 6 on Sediment Resuspension, Topical Response Number 7 on
Contingency Plans and Cleanups, Topical Response Number 8 on Glycol Chlorination,
and Topical Response Number 9 on Water Supplies and Treatment Costs.
LEBC-3 The potential for chlorination of hydrocarbons at water supply treatment facilities
was recognized in the DEIS as a possible impact (see Table 1-35 and paragraphs 4.023
and 4.073). The only portion of the Reference Program that has been identified as
an aspect which falls into an area of concern over chlorination is the release of
polyethylene glycol during an accident. Since the issuance of the DEIS, further
review has been performed concerning chlorination of polyethylene glycol (see
Topical Response Number 8 on Glycol Chlorination).
LEBC-4 See Topical Response Number 5 on the Great Lakes Water Quality Agreement of 1978,
the 1909 Boundary Waters Treaty, and the International Joint Commission.
LEBC-5 The DEIS included all five issues that are required by the Council on Environmental
Quality regulations 40 CFR 1500-1508. Chapter Four addresses the environmental
impacts of the proposed action and alternatives; the unavoidable adverse impacts;
and the irreversible and irretrievable commitment of resources. Chapter Four also
contains a discussion of the relationship between short-term uses of the environment
and enhancement of long-term productivity, and a discussion of mitigation.
Chapter Two is directed at all feasible alternatives to the Reference Program. The
comment does not delineate where the deficiencies in the analysis lie and thus
further response is not possible.
LEBC-6 Comment noted. See Topical Response Number 12 on the Need for Natural Gas.
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Job U/LERES2/p. 2
LEBC-7 The commenter is incorrect. The maps re'ferred to are both correct; the value on the
original referenced report shows a 4 as does the Lawler et al. map and the map
submitted with this comment. The seismicity of this region is rather well-
documented and is discussed in detail in paragraphs 1.053-1.056.
LEBC-8 The staff maintains that impacts of drillship operations in Lake Erie are addressed
adequately at the programmatic DEIS level. Site-specific impacts would be treated
in site-specific EIS's for natural gas development.
LEBC-8a The limited releases of gel and drill cuttings in the Reference Program will be
localized and are not expected to cause significant changes in bottom contours or to
change current patterns.
LEBC-8b Many compounds used in drilling deep Outer Continental Shelf (OCS) wells are not
needed in drilling the comparatively shallow wells described in the Reference Program
for Lake Erie. In addition, the only mud routinely discharged to the Lake in the
Reference Program is one composed of water and bentonite, a clay. Any other muds
are recycled and eventually disposed of onland. The impacts of accidental releases
are summarized in Table 4-5.
LEBC-8c Significant health risks are not identified. See Topical Response Number 6 on
Sediment Resuspension, Topical Response Number 8 on Glycol Chlorination, and Topical
Response Number 9 on Water Supplies and Treatment Costs.
LEBC-8d Statement of opinion noted.
LEBC-8e The site-specific nature of effects resulting from contaminant releases during the
drilling program was taken into account in'preparation of the DEIS. The approach
used in addressing water quality issues, for instance, was to make worst-case assump-
tions concerning parameters such as current speed and direction and contaminant
concentrations in order to estimate highest anticipated water-column concentrations.
The study referred to was designed to provide background data rather than serve as a
comprehensive impact assessment.
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Job U/LERES2/p. 3
LEBC-8f See Topical Response Number 9 on Water Supplies and Treatment Costs.
LEBC-9 See Response CCD-4.
LEBC-10 See Response UFF-7 and GLL-4.
LEBC-11 In most cases, mercury is not included in any corrosion protection device such as
sacrificial anodes, since these are currently in use in the Gulf Coast where mercury
contamination is equally important. Additionally, drilling rigs do not have heat
exchangers.
LEBC-12 For this type of gas well, it is doubtful that these wells would need servicing more
than once in the lifetime of the well. If necessary, however, it would more than
likely be a remedial stimulation that would not require a rig, and all returns would
be produced into the pipeline. Therefore, impacts would be negligible.
LEBC-13 Impacts resulting from pipe-laying operations from any type of barge are discussed
adequately. Additionally, the true costs of laying pipelines in deep areas of the
lake will be similar to the costs specified in the DEIS.
LEBC-14 Measures to mitigate erosion damage at a single point in a specific situation may be
inappropriate or ineffective on a lakewide basis. The comparison implied in this
comment is invalid.
LEBC-15 The Reference Program jack-up drilling rig is a state-of-the-art design, and it is
an excellent representation of what would actually be used. Since the construction
of the 'Timesaver II', it has been found that a four-legged jack-up is a much better
design because it presents a smaller surface area to any wave-generated forces.
LEBC-16 The Reference Program described in the DEIS is to be implemented in full compati-
bility with state and local land-use law, including applicable coastal zone manage-
ment (CZM) programs. At this time, no sites have been selected for any operations,
and so it is difficult to see how any conflicts with CZM programs could already have
arisen.
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Job U/LERES2/p. 4
LEBC-17 See Response EPA-4.
LEBC-18 The staff is not aware of definite conflicts with air quality implementation plans.
If such conflicts should arise in site-specific environmental impact assessments,
the appropriate new source permitting authority should be contacted in regard to the
need to apply for emission offsets. Nonattainment areas do not extend over Lake
Erie.
LEBC-19 The maximum number of vessels committed to the Reference Program includes eight
drilling rigs, three stimulation barges, three pipe barges, eight service vessels,
and three tow tugs. Minimal impact on Lake Erie port facilities and navigation can
be expected from this level of increased activity. Sufficient data are presented in
the DEIS to support this assessment (paragraphs 3.074-3.075 and 4.062-4.069).
LEBC-20 Comment noted.
LEBC-21 Statement of opinion noted.
LEBC-22 Statement of opinion noted.
LEBC-23 The issues raised in the comment regarding the estimation of U.S. Lake Erie gas
production has been considered by staff in projecting the amount of gas produced
from the development program. The assumptions used in estimating the production are
well documented in the DEIS.
The economic results of U.S. Lake Erie gas development calculated in terms of net
present value (NPV) and return on investment (ROI) are based on specific assumptions
about drilling success ratios, rate of gas -production, cost estimates, and price
increases. These assumptions can be very easily altered and results recalculated.
In the current analysis, positive NPVs and rates of ROI in the range of $41 million
to $850 million and 17% to 120% respectively have been estimated (see Table 1-36).
It has been also shown that a 20% decrease in the rate of gas production from the
base case may result in ROI in the range of 13 to 100%. An operator with limited
investment capital, guided by his profit maximizing motive, would direct his
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Job U/LEBES2/p. 5
resources to the project offering him Best return on his investment. Given the
opportunity of onshore drilling, which provides a higher rate of return than offshore
development, the operator would first allocate his limited resources to the onshore
gas development. The operator, if still left with some resources, would go for the
second best—which in the present context is the development of offshore gas—as
long as the ROI is higher than his opportunity cost. The economic choice of the
operator will depend upon the capital and the opportunities available.
In the staff's opinion, the assumptions used to derive the results are quite conser-
vative (e.g., the increase in the price of gas and the life of gas producing wells)
A rate of ROI in the range of 17 to 120% would not be considered as marginal.
LEBC-24 Position noted.
LEBC-25 The DEIS Reference Program is for natural gas development. Reference Program activity
impacts (including accidents) that would require additional treatment facilities or
chemicals are not identified.
LEBC-26 Position noted.
LEBC-27
Corrections to commenter's letter noted.
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DK-1 Statement of position noted.
Job V/LERES2/p. 1
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Job•W/LERES2/p. 1
TH-1 See Topical Response Number 12 on the Need for Natural Gas and paragraphs 1.010 to
-¦ 1.016 of the DEIS , which provide reasons for the implementation'of the Natural Gas
Policy Act, Energy Policy and Conservation Act, and the Powerplant and Industrial
Fuel Use Act. The reasons are, primarily, to conserve this nation's energy, reduce
dependency on other nations, and thus reduce the balance-of-trade deficit.
TH-2 See Topical Response Number 12 on the Need for Natural Gas. The past curtailments
were not used to justify gas development in Lake Erie. They were given as a his-
torical account leading to the lifting of bans for drilling in the Lake by the three
states. The purpose of this DEIS is to determine the environmental effects of gas
development under a program that results in the smallest possible release of mate-
rials to the environment; it is not a document intended to justify any action in the
Lake.
TH-3 The DEIS is an information document. Its purpose is to provide decision-makers,
including the general public, with information as to the environmental consequences
of a proposed governmental action. The DEIS is intended to provide this information
early in the decision-making process, before meaningful alternatives have been
foreclosed. It is intended to assure that when a choice is made, it is internal and
direct. The DEIS does not impose requirements. It cannot force anyone—government
official, company executive, or private individual—to do, or not do, any act or to
make any particular decision. Neither is anyone bound, at any time, to abide with
anything set forth in any EIS.
TH-4 The importance of natural gas to many major industries in the Lake Erie region was
discussed in the DEIS (paragraphs 1.018, 3.130-3.137, and 4.185).
Energy (natural gas) is an important factor for many industries. The development of
this resource could be an important factor in maintaining and attracting industries
to this region.
TH-5 See Topical Response Number 12 on the Need for Natural Gas. The industrial profile
presented on pages 3-42 to 3-50 of the DEIS reveals a heavily industrialized Lake
Erie region that is largely dependent upon natural gas as an energy source. Several
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Job W/LERES2/p. 2
counties in this region (Table 3-12) are' losing industry. Energy is emerging as an
important location factor for industry (paragraph 1.018). The development of a Lake
Erie natural gas resource could provide an economic impetus for industrial location
and expansion which is needed throughout the region.
TH-6 The description of the Task Force (paragraphs 1.063 and 1.064) does not commit, it to
any specific composition of viewpoints. Therefore, Mr. Heinrick is correct that
such a Task Force could exclude the environmental viewpoint. But the opposite is
not excluded either—i.e., environmentalists could be overrepresented. See also
Response EPA-11.
TH-7 These coal gasification options are discussed in greater detail in paragraphs 2.047
to 2.056. They are expected to play a role in the long-term national energy supplies.
The American Gas Association (1980) report estimates an annual production of about
1.5 to 3.5 trillion cubic feet of coal gas by the year 2000.
TH-8
See Response EPA-4.
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Job X/LERES2/p. 1
NCLW-1 Statement of position on U.S. Lake Erie'natural gas resource development is noted.
See Topical Response Number 6 on Sediment Resuspension, Topical Response Number 7 on
Contingency Plans and Cleanups, Topical Response Number 8 on Glycol Chlorination,
and Topical Response Number 9 on Water Supplies and Treatment Costs.
NCLW-2 Paragraph 3.041 provided a historic account of changes that occurred in the central
and western basin benthic communities as a result of anoxia and contaminant input.
The 1980 International Joint Commission report on Great Lakes Water Quality (page 11
of Appendix) does indicate that recent improvements have occurred. The presence of
the burrowing mayfly (Hexagenia limbata) at the mouth of the Detroit River has been
cited in the report as an indication of a trend toward significant improvement of
the benthic community. In the long term, effective programs to limit the input of
phosphorus still further and to reduce the input of organics and contaminants should
lead to still more improvement.
NCLW-3 Statement of opinion is noted. Operators would be required to obtain Corps of
permits prior to any gas development in U.S. Lake Erie. The permit review process
includes notification to the public of any proposal by public notice and includes
provisions for public hearings.
NCLW-4 See Response DOS-1. Also refer to paragraph 4.072 and Table 4-8.
NCLW-5 The economics provided are conservative, adequate, and meet National Environmental
Policy Act requirements. See Topical Response Number 9 on Water Supplies and Treat-
ment Costs. The staff agrees that there are many possibilities of cost overruns,
but the cost estimates used in the analyses are very conservative and are believed
to be reasonable. Also, the assumptions regarding gas production, the rate of cost
escalation, and the projected price of natural gas used for the revenue calculation
for Ohio are very reasonable and conservative. However, anyone using the results of
the economic analysis must keep in mind that the economic results of the Reference
Program represents one of many possible scenarios—any alteration in the assumptions
will change the results.
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Job X/LERES2/p. 2
The staff agrees that demand growth for'energy in the United States has decreased.
As per the energy forecasting model developed by DRI, Inc., natural gas demand in
the Middle Atlantic region (which includes Pennsylvania, New Jersey, and New York)
and the East Northcentral region (which includes Ohio, Indiana, etc.) will grow at
the rate of 1.6% and 0.7%, respectively, from 1980 to 1990. They also forecast the
amount of natural gas imported to be 3.5 TCF in 1990. Lake Erie gas may be utilized
to replace a portion of the imported gas, resulting in less dependence on the
outside energy resources.
NCLW-6 See Topical Response Number 7 on Contingency Plans and Cleanups. It is not clear
what question is being asked. If the question is, "How can we ensure that adequate
funds are made available to assure that environmental and ecological commitments are
in fact met?", then this DEIS details several mechanisms to ensure availability of
funds. These include: (1) development of accident contingency plans, and
(2) inclusion in lease contracts of provisions to insure financial responsibility,
e.g., bonding of the operator of the facility.
Undoubtedly, some commitment by government is implicit in any program that extends
into the future. The Reference Program contemplates a firm commitment by govern-
mental entities to provide the necessary ongoing funding to support carrying out
their responsibilities under the program. It is a truism, however, that availa-
bility of government funds in the future to meet government commitments made in the
past is subject to the political process and is never absolutely secure.
NCLW-7 - See Topical Response Number 6 on Sediment Resuspension and Topical Response
Number 12 on the Need for Natural Gas.
NCLW-8
Currently, no proposals to develop U.S. Lake Erie natural gas have been submitted to
the Corps of Engineers. The Corps permit process includes provisions for notifica-
tion to the public of proposals and provisions for public hearings.
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Job Y/LERES2/p. 1
UGD-1 See Responses EPA-2 and DEC-14.
UGD-2 To be provided.
UGD-3 The recommendation for a caisson; this item should not be considered as it is much
safer to place the wellhead in a caisson.
UGD-4 Drive pipe size is variable. A 16-inch drive pipe will work just as well as several
other sizes, and it serves quite nicely for the Reference Program. This also applies
to the comments about drill bits.
UGD-5
UGD-6
To be provided.
Statement of opinion noted.
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LERES3/Ref./1
References (Responses)
American Gas Association. 1980. The Gas Energy Supply Outlook: 1980-2000.
A report of the A.G.A. Gas Supply Committee. Prepared by the Policy
Evaluation and Analysis Group, Arlington, VA.
Amyx, J.W., D.M. Bass, and R.L. Whiting. 1960. Petroleum Reservoir Engi-
neering. McGraw-Hill Book Company, New York. 610 pp.
Britt, N.W. 1955. Stratification in western Lake Erie in summer 1953:
effects on the Hexagenia (Ephemeroptera) population. Ecology 36(2):239-
244.
Britt, N.W., E.J. Skoch, and K.R. Smith. 1968. Record low dissolved oxygen
in the island area of Lake Erie. Ohio J. Sci. 68(3):175-179.
Cleland, J.G., and G.L. Kingsbury. 1*977. Multimedia Goals for Environmental
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Protection Agency, Office of Research and Development, by Industrial
Enviromental Research Laboratory, Research Triangle Park, NC. Vol. 2.
Clifford, M.J. 1975. Preliminary Report on Potential Hydrocarbon Reserves
Underlying the Ohio Portion of Lake Erie. Ohio Div. Geol. Surv. Geol.
Note No. 1. 9 pp.
Ferrante, J.G., E.H. Dettmann, and J.I. Parker. 1980. Natural Gas in Lake
Erie: A Reconnaissance Survey of Discharges from an Offshore Drilling
Rig. ANL/ES-85. Argonne National Laboratory, Argonne, IL. 61 pp.
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LERES3/Ref./2
Herdendorf, C.E. (ed.). 1980. Lake Erie Nutrient Control Program: An Assess-
ment of Its Effectiveness in Controlling Lake Eutropbication. EPA-600/3-
80-062. Environmental Research Laboratory, Duluth, MN. 63 pp.
International Institute for Applied Systems Analysis. 1981. Energy in a
Finite World. [As summarized by Chemical Engineering News 59(11):6-7
(March 16, 1980).]
International Joint Commission. 1980. Water Quality of the Great Lakes,
(see NCLW-2).
Lawler, Matusky & Skelly Engineers. 1977. Environmental Assessment--Development
of Offshore Natural Gas Resources, New York State Waters of Lake Erie.
LMS Project No. 266-002., Prepared for New York State Department of
Environmental Conservation, Tappan, NY. 1 v. (various pagings).
McGraw-Hill, Inc. 1978. Natural gas/fuel FORECAST. Series A, Geographic.
New York, NY. A v. (Vol. Al, East Coast; Vol. A2, Midwest).
McGregor, D.L., et al. 1978. An Examination of Issues Related to U.S. Lake
Erie Natural Gas Development. ANL/ES-68. Prepared for the U.S. Army
Corps of Engineers and the U.S. Environmental Protection Agency by the
Division of Environmental Impact Studies, Argonne National Laboratory,
Argonne, IL. 194 pp.
Michael, D.I., and C.E. Herdendorf. 1980. Anticipated Environmental Impacts
Related to the Development of Natural Gas and Oil in the United States
Waters of Lake Erie. CLEAR Tech. Rep. No. 132. Ohio State University,
Center for Lake Erie Area Research, Columbus, OH.
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IERES3/Ref,/3
National Research Council. 1979. Energy in Transition, 1985-2010. Final
Report of the Committee on Nuclear and Alternative Energy Systems. W.H.
Freeman and Company, San Francisco, CA.
Ongley, E.D. 1976. Sediment yields and nutrient loadings from Canadian
watersheds tributary to Lake Erie: an overview. J. Fish. Res. Board
Can. 33:471-484:
Sachs, M.Y., G.M. Horn, et al. (eds.). 1981. World Mark Encyclopedia of the
States. World Mark Press, Ltd.; Harper and Row, New York.
Stevenson, A.J., R.J. Green, et al. (eds.). 1972. Webster's New Geographical
Dictionary. G & C Merriam Co., Publishers, Springfield, MA.
U.S. Environmental Protection Agency. 1980. Acid Rain. EPA-600/9^79-036.
Office of Research and Development, Washington, DC. 36 pp.
Welch, H.E., J.W.M. Rudd, and D.W. Schindler. 1980. Methane addition to an
arctic lake in winter. Limnol. Oceanogr. 25(1):100-113.
Zapotosky, J.E., and C.E. Herdendorf. 1980. Oxygen depletion and anoxia in
the central and western basins of Lake Erie, 1973-1975, pp. 71-102. In
C.E. Herdendorf (ed.), Lake Erie Nutrient Control Program: An Assessment
of its Effectiveness in Controlling Lake Eutrophication. EPA-600/3-80-062.
Zapotosky, J.E., and W.S. White. 1980. A Reconnaissance Survey for Volatile
and Nonvolatile Hydrocarbons in the Central and Eastern Basins of Lake
Erie: September 1978. ANL/ES-87. Argonne National Laboratory,
Argonne, IL. 150 pp.
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