Conclusions

Conclusions

Conclusions

HVHF is a complex activity that could affect many communities in New York State. The
number of well pads and associated HVHF activities could be vast and spread out over
wide geographic areas where environmental conditions and populations vary. The
dispersed nature of the activity magnifies the possibility of process and equipment
failures, leading to the potential for cumulative risks for exposures and associated
adverse health outcomes. Additionally, the relationships between HVHF environmental
impacts and public health are complex and not fully understood. Comprehensive, longterm
studies, and in particular longitudinal studies, that could contribute to the
understanding of those relationships are either not yet completed or have yet to be
initiated. In this instance, however, the overall weight of the evidence from the

cumulative body of information contained in this Public Health Review demonstrates
that there are significant uncertainties about the kinds of adverse health outcomes that
may be associated with HVHF, the likelihood of the occurrence of adverse health
outcomes, and the effectiveness of some of the mitigation measures in reducing or
preventing environmental impacts which could adversely affect public health.
While a guarantee of absolute safety is not possible, an assessment of the risk to public
health must be supported by adequate scientific information to determine with
confidence that the overall risk is sufficiently low to justify proceeding with HVHF in New
York. The current scientific information is insufficient. Furthermore, it is clear from the
existing literature and experience that HVHF activity has resulted in environmental
impacts that are potentially adverse to public health. Until the science provides sufficient
information to determine the level of risk to public health from HVHF and whether the
risks can be adequately managed, HVHF should not proceed in New York State.

Background

In 1992, the NYS Department of Environmental Conservation (DEC) finalized the
Generic Environmental Impact Statement (1992 GEIS) on the Oil, Gas and Solution
Mining Regulatory Program.1,2 Conventional natural gas development in NYS –
including the use of low-volume hydraulic fracturing – has been permitted by DEC under
the GEIS since that time. High-volume hydraulic fracturing (HVHF), which is often used
in conjunction with horizontal drilling and multi-well pad development, is an approach to
extracting natural gas that raises new, potentially significant, adverse impacts that were
not studied in the 1992 GEIS. Therefore, in 2008 DEC began the process of developing
a supplement to the GEIS (hereafter the draft SGEIS) specifically addressing natural
gas development using HVHF and directional drilling in unconventional formations such
as the Marcellus and Utica Shales (collectively referred to here as HVHF shale-gas
development).
In 2012, DEC requested that the New York State Department of Health (DOH) review
and assess DEC’s analysis of potential health impacts contained in DEC’s draft
supplemental generic environmental impact statement (draft SGEIS3) for HVHF. In
response to the original request from DEC, DOH initiated an HVHF Public Health
Review process. DOH has a long history of working closely with DEC on all DEC
programs that have public health components. DOH has extensive expertise in
environmental health, including protecting drinking water supplies, environmental
radiation protection, toxicology, environmental exposure assessment, occupational
health, and environmental epidemiology. DOH also collects, manages, and analyzes
extensive public health surveillance data for all of New York State.

DOH is charged with defending the public health of New Yorkers. In order to meet this
charge with respect to HVHF, DOH reviewed and evaluated relevant emerging scientific
literature that investigated the environmental health and community health dimensions
of HVHF. The literature was assessed in terms of the adequacy of the current science
to inform questions regarding public health impacts of HVHF. As part of this review,
DOH also sought input from three outside public health expert consultants, engaged in
discussions and field visits with health and environmental authorities in states with
HVHF activity, and held numerous meetings with local, state, federal, international,
academic, environmental, and public health stakeholders. The evaluation considered
the available information on all potential pathways that connect HVHF activities and
environmental impacts to human exposure and the risk for adverse public health
impacts.
HVHF shale-gas development is a large-scale, complex issue that potentially could
affect a significant portion of New York State. In order to make an informed assessment
of the potential public health consequences of HVHF in New York, the totality of
available information from relevant sources has to be evaluated collectively. A single
study or isolated piece of information will not provide a complete public health picture for
such a complex activity. In assessing whether public health would be adequately
protected when allowing a complex activity such as HVHF to go forward, a guarantee of
absolute safety is not required, but there must be sufficient information to understand
what the likely public health risks will be. Ultimately, in conducting this Public Health
Review, DOH evaluated the relevant lines of available evidence collectively, and made
a judgment on whether the scientific information was adequate to determine the level of
public health risk.