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We, the undersigned organizations, thank you for the opportunity to comment on NYSDEC’s proposed revisions to the Part 370 series Hazardous Waste regulations. Our organizations are calling on NYSDEC to use this opportunity to close what is commonly known as the “hazardous waste loophole,” which exempts oil and gas waste from being classified as hazardous waste.

Many of the undersigned organizations also submitted comments during NYSDEC’s 2017 rulemaking on the Part 360 series Solid Waste Management regulations. Many improvements to address oil and gas waste were made through that rulemaking; however, critically, the hazardous waste loophole was not closed.

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