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Thank you for the opportunity to submit written comments on Proposed 6 NYCRR Part 570, Regulation of Liquefied Natural Gas Facilities.

Earthworks is a nonprofit organization dedicated to protecting communities and the environment from the impacts of irresponsible mineral and energy development while seeking sustainable solutions. For over two decades, we have worked nationwide to advance policy reforms, improve corporate practices, and safeguard land and public health. The Oil & Gas Accountability Project (OGAP) of Earthworks works with local communities, landowners, organizations, agencies, and elected officials to advance these goals.

We recognize the effort that the Department of Environmental Conservation has made to update the state’s regulations for Liquefied Natural Gas (LNG) facilities in light of the current shale gas boom and the potential lifting of the moratorium on facilities that has been in place since 1973. We also understand that there is growing interest on the part of the natural gas industry and energy providers to expand LNG operations in New York.

However, Earthworks views the proposed draft regulations as far too narrow and vague to protect public health, air quality, and the climate from the environmental impacts of LNG facilities. Below we provide information regarding several aspects of the draft regulations that the DEC must address before it promulgates final rules.

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