Christopher M. Hogan

New York State Department of Environmental Conservation: Division of Environmental Permits

625 Broadway, 4th Floor

Albany, NY 12233-1750

RE: Dominion New Market Project Air State Facility Permits:

Application ID: 4-2730-00038/00001- Brookman Corners Compressor Station

Application ID: 7-2530-00033/00001- Sheds Compressor Station

Application ID: 8-0740-00081/00001- Horseheads Compressor Station

Dear Mr. Hogan,

The Otsego County Conservation Association, Inc. (OCCA) is writing to the New York State Department of Environmental Conservation (DEC) to express support for the comments of Otsego 2000, Mohawk Valley Keeper, Mothers Out Front, and the Madison County Neighbors for Environmental Preservation (Otsego 2000 et al.) on the draft Air State Facility Permits for the Dominion “New Market” Project. Founded in 1968, OCCA is a 501(c) (3) nonprofit organization based in the Town of Springfield. OCCA is dedicated to promoting the appreciation and sustainable use of Otsego County’s natural resources through education, advocacy, resource management, research, and planning.

The comments of Otsego 2000 et al. establish a clear, scientific, and thorough case for the denial of the draft Air State Facility Permits for the Dominion “New Market” Project. In particular, OCCA would like to emphasize the following points made in Otsego 2000’s comments:

  • The Applicant’s use of modeling data from regional airports is not a suitable substitute for localized air quality testing along the project route.
  • The Applicant failed to consider the effects of the proposed project on Amish and Mennonite populations living near the project route.
  • If approved, the proposed project would directly conflict with Governor Cuomo’s Clean Energy Standard.
  • The Applicant failed to appropriately evaluate the health impacts of episodic emissions.
  • The Applicant failed to appropriately inventory all residents and vulnerable communities in their modeling data.

As proposed, OCCA believes the air emissions permits lack the appropriate modeling data, do not demonstrate how the proposed project will fully mitigate greenhouse gas emissions, create the potential for adverse health impacts on rural populations, and could exacerbate the effects of climate change. If the project is approved, OCCA strongly believes that the DEC should require the Applicant to implement mitigation measures that utilize the best available technology. OCCA joins Otsego 2000 et al. in urging the DEC to deny all three permits and steer New York toward a better future.

Respectfully submitted,

Vicky Lentz, President