To: David Bimber, Deputy Regional Permit Administrator, NYSDEC

From: Steve Coffman
To: David Bimber, Deputy Regional Permit Administrator, NYSDEC
January 21, 2011

Dear Administrator Bimber:
In reference to the Finger Lakes LPG Storage project in Salt Caverns near Seneca Lake in Schuyler County, I find this to be an extremely unfortunate and shortsighted project.
Undoubtedly, you have received numerous comments on the many spills and explosions that have occurred in similar projects across the nation. While those accidents are indeed worrisome, my emphasis specifically concerns Seneca Lake.
Seneca Lake is the heart and anchor of the Finger Lakes, not only centrally located but containing 50% of the Finger Lakes’ waters. For the Finger Lakes to remain healthy as a resource and viable to a burgeoning region, Seneca Lake must be protected at all costs.
A 2006 study by Hobart & William Smith’s Finger Lakes Institute portrayed Seneca Lake as a body of water on the brink of unreclaimable contamination. While some slow progress has been made since that report, this proposed project takes our region in exactly the wrong direction for community as well as environmental reasons.
The Finger Lakes are one of the largest sources of fresh water wholly within the United States (the Great Lakes being shared with Canada, of course). I hardly need to point out the importance of fresh water in a world where that most precious of resources is becoming evermore scarce. And what that means for us in the Finger Lakes, as well as for NYS and DEC, is that we have a particular obligation to be long-sighted in this respect.
Perhaps, asking DEC to consider “moral imperatives” is unusual and beyond the parameters of GEIS scoping; however, such a consideration is vital to the future well-being of the Finger Lakes Region, not only for its agriculture, wineries, growing agri-tourism, esthetic qualities, retirement appeal and Mennonite communities, but for the intrinsic value of the water itself. All of these elements fall well within the mission of DEC.
Without doubt, the nation needs energy and LPG is presently an important component of that need, which may necessitate bypassing certain local dissatisfactions, perhaps even weigh against certain “acceptable” risks. But there are things that cannot be put on the bargaining table, and the essence of the Finger Lakes and the value of its waters belong in that non-negotiable category, even if certain local officials are too shortsighted to realize their obligations.
It is for just such necessary oversight that DEC exists.
Finally, I clearly recall when, in conjunction with a proposed waste-to-energy garbage incinerator in our region, it was recommended that the Retsoff Salt caverns would be an ideal receptacle for toxic fly ash from the incinerator.
DEC even referred to the Retsoff salt formation as “essentially eternal,” a description that proved considerably over-optimistic when, as I’m sure you recall, portions of the formation collapsed before the proposal was even off the table, doing considerable damage to many wells and the poor old Genesee River. One can only imagine what the extent of the damage might have been had 20 or 30 years of concentrated toxic incinerator fly ash been added to that salty mess.
Rather than risking repetition of such an overly-optimistic assessment when it comes to the salt caverns adjacent to Seneca Lake, what is required here is an intensely-skeptical approach, which, I have no doubt would lead to the rejection of this half-baked and shortsighted plan.
Thank you.
Steve Coffman

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