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Dear New York State Energy Planning Board:

Thank you for the opportunity to comment on the 2014 Draft New York State Energy Plan. Founded in 1988, Earthworks is a nonprofit organization dedicated to protecting communities and the environment from the negative impacts of mineral and energy development while seeking sustainable solutions.

Like every other state in an era of accelerating climate change and fossil fuels that are more difficult to access, New York confronts significant economic, social, and environmental challenges in meeting energy demand.

On the one hand, the 2014 Draft Energy Plan boldly addresses this reality by emphasizing growth in renewable energy and green jobs, more efficient electricity and transportation systems, and technological and market innovation. New York deserves additional credit for emphasizing the critical role of health, environmental justice, and climate impacts in energy planning.

On the other hand, the Plan maintains status quo thinking about energy options. The Plan presumes that because New York is currently a high consumer of natural gas, the state must continue to expand its use of natural gas and build a future of more pipelines, compressor stations, processing facilities, and drilling waste dumps. Yet the state does not spell out what this type and scale of expansion would mean for New York’s air and water quality and the health and safety of its residents. Such issues have only become more critical in light of the March 12 explosion in Harlem that claimed eight lives, apparently due to a leaking natural gas line.

While aging gas lines may need to be replaced to ensure safety, expanding and building new gas processing and delivery infrastructure would only increase future risks. In the following pages, Earthworks details its concerns about increasing New York’s reliance on natural gas and the negative environmental and health impacts of associated infrastructure. Such investments would put New Yorkers at risk of serious harm and would increase demand for risky drilling in other states that would endanger air, water, homes and health.

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