The Supplemental Generic Environmental Impact Statement (SGEIS) presents a comprehensive review of ecological effects due to water withdrawal for High Volume Hydraulic Fracturing (HVHF) . The document refers to the impact of water withdrawal for HVHF on streams, water tables, wetlands, aquifers, and other topics. The SGEIS explicitly refers to the cumulative impact of 40,000 wells over the next 30 years, which is praiseworthy, although omission of the volume of water used for multiple re -fracking events leads to a significant error in their calculations of water use. The ecological comments indicate a well informed concern for the natural, aquatic processes that might be influenced by HVHF. Further, the SGEIS also says (page 6-8) "The recently enacted Water Resources Law extends the Department's authority to regulate all water withdrawals over 100,000 gpd (gallons per day) throughout all of New York State. This law applies to all such withdrawals where water would be used for high-volume hydraulic fracturing. Withdrawal permits issued in the future … allow the Department to monitor and enforce water quality and quantity standards, and requirements." Collectively, this suggests awareness and concern for protecting aquatic habitats and a mechanism for the DEC to do so.

On the other hand, the SGEIS seriously misrepresents the ecological impact of withdrawal for HVHF, which appears to lead to the SGEIS comment: "The amount of water withdrawn specifically for high-volume hydraulic fracturing also is projected to be relatively low when compared to existing overall levels of water use" (page 6-12). To my mind, this is a very significant deception as described below.

The SGEIS says (page 6-10) "While projected water withdrawals and consumptive use of water are modest relative to overall water withdrawals in New York, there remains the potential for adverse impacts particularly when withdrawals take place during low-flow or drought conditions." The DEC bases this estimated modest impact on the following calculation (page 6-10): "Multiplying the peak projected annual wells by current average use per well results in calculated peak annual fresh water usage for high-volume hydraulic fracturing of 9 billion gallons. Total daily fresh water withdrawal in New York has been estimated at approximately 10.3 billion gallons. This equates to an annual total of about 3.8 trillion gallons. Based on this calculation, at peak activity high-volume hydraulic fracturing would result in increased demand for fresh water in New York of 0.24%"(emphasis added).

However, the estimate of an index value of 0.24% for the ecological effect of water used for HVHF is too low by at least two orders of magnitude because of three sources of error.

First, the SGEIS compares lemons to apples by comparing the amount of water that is withdrawn and consumed for HVHF to the amount of water that is withdrawn and returned by other uses. The SGEIS emphasizes the distinction between used and borrowed but returned in the text just two paragraphs before presenting the calculation (page 6-9) and graphically presents this distinction just two pages later in Figure 6.3. The important distinction between water used and water recycled is illustrated by values for the Delaware River Basin (Figure 6.3). The figure shows that most of the water that is withdrawn is used for cooling electric power plants and almost all of that water, about 98.4%, returns from the plant to the hydrological cycle. Values in Figure 6.3 show that overall 96.3% of all water that is withdrawn is returned to the hydrological cycle. In contrast, the SGEIS says that "withdrawals for hydraulic fracturing are considered as 100 percent consumptive losses because this water is essentially lost to the basins' hydrologic cycle" (page 6-9). The calculated 0.24% increase in water demand due to HVHF is derived by comparing the amount of water withdrawn and used by HVHF to the amount of water withdrawn by all other actions without considering that almost all of the water withdrawn for other uses is actually returned to the hydrological cycle.

To indicate the relative impact of water consumed by HVHF, the value should be derived from the ratio of 9 billion gallons annual use for HVHF divided by a withdrawal volume that is corrected for the very large return. Using the SGEIS value of 96.3% return (Fig. 6.3), the corrected estimate of ecological impact for HVHF would be 6.4%.

Further, this portion of the SGEIS assumes that each well is fracked only once, whereas some projections suggest that multiple re-fracking of wells to stimulate more gas flow throughout the life time of a well will be common. Multiple refracking would increase the volume of water used several-fold.

Further, and to my mind most blatantly deceptive, the estimate of ecological impact of water use for HVHF compares water used for HVHF in a localized part of the state to water withdrawn for the entire state. A realistic index of the ecological effect of water withdrawal for HVHF would compare water used for fracking to other water uses within the area where fracking will occur. This correction would greatly increase the relative impact of HVHF. I do not have the resources to make the appropriate corrections, but correcting for re-fracking, and for water return, and basing the index on local water usages would make the estimated ecological impact on the order of ~50-fold greater than described in the SGEIS.

Part of the SGEIS presents an extensive summary of potential impacts of HVHF on water resources and describes an effective legal mechanism to regulate water use. Part of the SGEIS presents a deliberately deceptive index of the ecological effect of HVHF. This raises doubts about the DEC commitment to protecting aquatic resources. The DEC has had to cut many staff positions. It does no good for the SGEIS to include wonderful descriptions of the ecological factors that need to be monitored for wildlife and water if there is no one in the DEC to do it. The incorrect calculations that suggest water use will be relatively minimal may lead to, or be part of, a DEC perception that monitoring of aquatic ecosystems is not important. The DEC conclusion that the "… projected water withdrawals and consumptive use of water are modest relative to overall water withdrawals in New York" (page 6-10) is misleading and selfdeceiving. Unless this perception is changed, we have little reason to believe that our DEC will spend their resources of personnel and money to protect our aquatic resources from the effect of water use by HVHF.