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E. Tetz & Sons, Inc. - Ruling, March 20, 2003

Ruling, March 20, 2003


In the Matter of the Application of

E. Tetz & Sons, Inc.
March 20, 2003
for an Air State Facility Permit pursuant
to Article 19 of the Environmental Conservation
Law ("ECL"), a State Pollutant Discharge
Elimination System ("SPDES") permit pursuant to
Article 17 of the ECL, a Protection of Water
permit pursuant to Article 15 of the ECL, a
Mined Land Reclamation Permit pursuant to
Article 23 of the ECL, and a Water Quality
Certification pursuant to Section 401 of
the federal Clean Water Act.

DEC #3-3352-00255/00001


The Administrative Law Judge ("ALJ") rules: 1) none of the four issues proposed for adjudication by the Intervenors meet the standard to be advanced to adjudication; 2) the Intervenors have not satisfied the requirements necessary to be afforded party status; and 3) that the matter should be remanded to the Staff of the Department of Environmental Conservation ("DEC Staff") in order to issue the permits.


The Applicant, E. Tetz & Sons, Inc., proposes to construct a continuous flow hot-mix asphalt plant on 7.7 acres of a 10.9 acre parcel located on Crotty Road in the Town of Wallkill (the "site"). In order to mitigate for the loss of wetlands at the site, the Applicant proposes to conduct wetlands mitigation off-site, at a location in the Town of Wawayanda.

On the site, the Applicant proposes to construct a plant consisting of a drum burner, four 200-ton asphalt storage silos, two 30,000-gallon liquid asphalt storage tanks, two 1,000 gallon asphalt emulsion tanks, one 10,000 gallon fuel oil tank, an 800 kW diesel generator, and a bag house. The maximum annual capacity of the plant is proposed at 500,000 tons of asphalt. The operation of the plant will require state air pollution control and State Pollutant Discharge Elimination System ("SPDES") stormwater discharge permits. Stormwater discharges during construction will be regulated by a general SPDES permit, GP-93-06. When the proposed project becomes operational, the Applicant will receive an individual industrial SPDES stormwater permit (SPDES No. NY-0264997).

The Air State Facility permit will restrict the potential to emit from this proposed facility through federally enforceable permit conditions which will limit air emissions at a level below the applicability thresholds for Title V, and NOx RACT regulations. These applicability thresholds include 100 tons per year for NOx, SO2, and CO, and 50 tons per year for VOCs. By accepting federal and state enforceable limits, the Applicant will not be subject to these regulations and the facility will not be subject to state New Source Review requirements. However, the proposed project will be subject to federal New Source Performance Standards (40 CFR Part 60 subpart I - Standards of Performance for Hot Mix Asphalt Facilities).

The Applicant has agreed to permit conditions that limit emissions of the above air pollutants by restricting asphalt production to a maximum of 500,000 tons per year and by restricting generator hours to 4,000 per year. The Applicant will be required to maintain records and report data to verify compliance with permit conditions and emission limits.

Construction of the proposed plant will involve the filling of approximately 2.32 acres of federally-regulated wetlands on the site. A Clean Water Act Section 404 wetland permit was issued by the U.S. Army Corps of Engineers ("ACOE") for this activity on June 6, 2000. This permit has since expired and the Applicant has indicated it will reapply for a new ACOE permit. Before work can be commenced pursuant to an ACOE permit, a Section 401 Water Quality Certification ("WQC") must be issued by DEC Staff. Wetland losses will be mitigated through the creation of approximately 3 acres of replacement wetlands at E. Tetz & Son's Pine Lane Mine located off U.S. Route 6 in the Town of Wawayanda. The mitigation site is located near the banks of a sub-tributary of Monhagen Brook (DEC Water Index No. H-139-13-52-2-1a; Class B). Use of the Pine Lane Mine site for wetland mitigation requires a new Protection of Waters permit and modification of the existing Mined Land Reclamation Permit.


The Wallkill Town Planning Board is the lead agency under the State Environmental Quality Review Act ("SEQRA"), Article 8 of the Environmental Conservation Law ("ECL") and its implementing regulations, Part 617 of Title 6 of the New York Code of Rules and Regulations ("6 NYCRR"). The Department of Environmental Conservation ("DEC") is an involved agency. While not relevant to this Ruling, litigation regarding approval of this proposed project by the lead agency is in progress. Below is a brief summary of the litigation to date, as it is reported in the record.

On March 25, 1998, the lead agency determined that the proposed project may have a significant impact on the environment and required the preparation of a Draft Environmental Impact Statement ("DEIS"). On April 11, 2000, the lead agency accepted the Final Environmental Impact Statement ("FEIS"). On July 5, 2000, the lead agency voted to deny a special use permit for the proposed project, and in September of that year the lead agency issued its findings.

On December 7, 2001, Acting NYS Supreme Court Justice Peter M. Leavitt vacated the lead agency's findings because the lead agency relied on information not in the SEQRA record to make its findings. Justice Leavitt remanded the matter back to the lead agency to make findings based upon information in the record. The Appellate Division refused to hear the appeal. On October 30, 2002, the lead agency adopted new SEQRA findings and again denied the proposed project. The Applicant again sued. On December 18, 2002, NYS Supreme Court Justice Francis A. Nicolai denied Applicant's motion to find the lead agency in contempt. The litigation continues.


A Notice of Public Hearing was published on December 18, 2002 in DEC's Environmental Notice Bulletin and in the Middletown Times Herald Record on December 18, 2002.


The DEC permit hearing process began on January 28, 2003 with a legislative hearing to receive unsworn statements about the application. The legislative hearing was held at the Wallkill Community Center, 8 Wes Warren Drive, Wallkill, New York. Approximately forty (40) people attended. Ten (10) individuals spoke at the hearing including representatives of the Applicant, DEC Staff, and the Intervenors. Only the Applicant's representative spoke in favor of the project and eight (8) other people either spoke in opposition to it or voiced concerns regarding the impacts of the proposed project.


The deadline for filing for party status was January 24, 2003. One petition for full party status was timely received proposing four issues for adjudication. The petition was made on behalf of the following individuals and business owners: Robert M. Jaffee, M.D., Hal Teitelbaum, M.D., Daniel Reidy, Rose Reidy, Silvio DiIorio, Victor Rossi, Walter Hoyt, Antonio Ciccone, and Maria Ciccone (collectively "Intervenors").


An issues conference was held on January 31, 2003, Wallkill Community Center, 8 Wes Warren Drive, Wallkill, New York.

Appearing for the Applicant was Rosemary Stack, Esq. Also attending on behalf of the Applicant were: Gary Tetz, vice-president of the Applicant, James Ullrich from Alpine Environmental Consultants, Joseph McMullen from Terrestrial Environmental Specialists, and Thomas DePuy from T.M. DePuy Engineering and Land Surveying, P.C.

DEC Staff was represented by Jonah Triebwasser, Esq., Assistant Regional Attorney. The following members of DEC Staff also attended: Thomas Rudolph, Patrick Ferracane, Thomas Miller, Scott Sheeley, Mark Davin, William Steidle, and Vincent Altieri, Esq.

The Intervenors were represented by James Bacon, Esq. Also attending for the Intervenors was Ralph Huddleston from Carpenter Environmental Associates.


The record of the Issues Conference closed on February 18, 2003 with the receipt by the ALJ from the Applicant of a copy of the final Issues Conference Exhibit.


The standard for determining whether any issue proposed should be adjudicated is found at 6 NYCRR 624.4(c). When DEC Staff has determined that a permit application, conditioned by a draft permit, will meet statutory and regulatory requirements (as is the case here), the potential party proposing an issue has the burden of persuasion to demonstrate that the proposed issue is substantive and significant.

An issue is substantive if there is sufficient doubt about the applicant's ability to meet statutory or regulatory criteria such that a reasonable person would inquire further (6 NYCRR 624.4(c)(2)). An issue is significant if it has the potential to result in the denial of a permit, a major modification to the proposed project or the imposition of significant permit conditions in addition to those proposed in the draft permit (6 NYCRR 624.4(c)(3)).

In order to establish that adjudicable issues exist, "an intervener must demonstrate to the satisfaction of the Administrative Law Judge that the Applicant's presentation of facts in support of its application do not meet the requirements of the statute or regulations. The offer of proof can take the form of proposed testimony, usually that of an expert, or the identification of some defect or omission in the application. Where the proposed testimony is competent and runs counter to the Applicant's assertions an issue is raised. Where the intervener proposes to demonstrate a defect in the application through cross-examination of the Applicant's witnesses, an intervener must make a credible showing that such a defect is present and likely to affect permit issuance in a substantial way. In all such instances a conclusory statement without a factual foundation is not sufficient to raise issues" (Matter of Halfmoon Water Improvement Area, Decision of the Commissioner, April 2, 1992).

In cases, such as this one, where DEC is not the lead agency under SEQRA, no issue that is based solely on compliance with SEQRA and not otherwise subject to DEC's jurisdiction will be considered for adjudication unless DEC Staff notified the lead agency during the comment period on the DEIS that the DEIS was inadequate or deficient with respect to the proposed issue and the lead agency failed to adequately respond. In this case, DEC Staff did not notify the lead agency of inadequacies or deficiencies that were not addressed.


The first issue proposed by the Intervenors is that the lead agency, the Wallkill Town Planning Board, improperly applied SEQRA to the project. The Intervenors propose two sub-issues. First, the Intervenors argue that the lead agency should be required to produce a Supplemental Environmental Impact Statement ("SEIS") because the traffic studies included in the FEIS did not accurately estimate the amount of additional traffic resulting from the project. Second, the Intervenors argue that the Applicant's wetland mitigation plan was not reviewed by the lead agency during its SEQRA process. The Applicant cites ECL §3-0301(1)(b) as authority for the ALJ to hear this issue in a DEC permit hearing. Section 3-0301(1)(b) authorizes the Commissioner to take into account the cumulative impact in any determination to issue a DEC permit.

The Applicant responds that the DEC hearing process is not the appropriate forum for either of the Intervenors' proposed sub-issues because DEC is not the lead agency and DEC Staff made no comments to the lead agency regarding traffic impacts (6 NYCRR 624.4(c)(6)(ii)). Thus, procedurally and legally, neither the DEC ALJ nor the Commissioner of DEC have the authority to require a lead agency to prepare an SEIS. The decision to require an SEIS is solely the lead agency's, and in this case the Intervenors' requests to the lead agency to require an SEIS have been rebuffed.

Addressing the substance of the Intervenors' first sub-issue, the Applicant asserts that the traffic studies included in the FEIS are accurate and that the Intervenors' estimates of traffic impacts are erroneous. DEC Staff experts agree with the Applicant that the expected traffic impacts were not inconsistent with the FEIS record and that an SEIS is unnecessary.

With respect to the substance of the Intervenors' second sub-issue, the Applicant asserts that the wetland mitigation plans were before the lead agency when it accepted the FEIS and only very small details of the plans have changed, at the request of the ACOE and DEC Staff. DEC Staff also supports the Applicant's contentions regarding the wetlands mitigation plan that no SEIS is needed and all relevant information was considered in the FEIS.

Ruling 1: Neither of these two proposed sub-issues are advanced to adjudication. The DEC hearing process is not the appropriate forum to hear these issues. The DEC permit hearing regulations are unambiguous on this point (6 NYCRR 624.4(c)(6)(ii)). SEQRA does not empower the DEC Commissioner to require a lead agency to prepare an SEIS nor is the conduct of the lead agency reviewable in a DEC permit hearing. Intervenors' reliance on the general powers of the Commissioner is misplaced.


The second issue proposed by the Intervenors is purely a legal question. The Intervenors argue that since the lead agency made findings and denied approval of a local special use permit of the project, DEC cannot issue findings contrary to the lead agency, and issue the state environmental permits that are the subject of this hearing.

Both the Applicant and DEC Staff reject this rather novel interpretation of SEQRA's requirements regarding agency findings (6 NYCRR 617.11). They argue that SEQRA requires each agency to undertake its own independent review of the FEIS and issue its own independent finding statements. An agency's independent findings are not binding on other agencies' findings (Ardizzone v. Elliot, 141 A.D.2d 632 (2d Dept. 1988), rev'd on other grounds 75 N.Y.2d 150 (1989)).

Ruling 2: The legal question of whether the DEC Commissioner can make independent findings or is bound by the findings of the lead agency is not advanced to adjudication. An involved agency is not obligated to make the same findings as the lead agency. This reflects differing agency perspectives toward balancing various factors.

INTERVENORS' PROPOSED ISSUE #3 - Federal Wetland Permit Issues

The third issue proposed for adjudication by the Intervenors is that DEC Staff cannot issue the WQC pursuant to section 401 of the federal Clean Water Act ("CWA") until the ACOE issues a new federal wetland permit.

As described above, the proposed project will involve the filling of approximately 2.32 acres of federally-regulated wetlands on the site. There are no state regulated wetlands at the site and no state wetland permit is required. The Applicant had applied for and received a CWA Section 404 wetland permit from the ACOE for this activity on June 6, 2000. However, this permit expired on February 11, 2003. The Applicant's permit was issued pursuant to a general permitting program (Nationwide Permit No. 26) that has also expired. Thus, the Applicant must now apply for an individual federal wetlands permit from the ACOE. Both the expired and new federal permits require a Section 401 WQC from the DEC Staff.

The Intervenors raise three sub-issues regarding the federal wetlands permit and WQC. First, without stating any basis for their assertion, the Intervenors contend that as a matter of law it is premature for DEC Staff to issue the WQC before a new federal wetlands permit is issued. Second, the Intervenors' expert asserts that the Applicant cannot meet the standards for the issuance of an individual federal wetlands permit because the criteria for a new individual permit are different from those for the expired general permit and, consequently, the entire project will need to be redesigned. Finally, Intervenors argue that this issue was not reviewed by the lead agency pursuant to SEQRA.

Regarding the first sub-issue, Applicant counters that DEC regulations (Parts 608 and 621) do not require that a federal wetland permit be issued before DEC Staff can issue a WQC. The Applicant maintains that it is often the practice that the WQC is issued prior to the federal wetlands permit. DEC Staff agrees with the Applicant that both a federal wetland permit and a state WQC are needed for the project, but concurs that the order in which those permits are issued is of no consequence. Intervenors cite no authority for their claim that the ACOE permit must be issued before a WQC is issued and, therefore, the state permit process must be held in abeyance.

Regarding the second sub-issue, the Applicant's expert asserts that the standards for the new individual ACOE permit are the same or similar to those for the general permit and that the project will not have to be redesigned. The DEC Staff expert also agrees with the Applicant that the substantive review of the proposed project for an individual permit would not be substantially different from the review under the expired general permit. In any event, this dispute among experts regarding whether the project as proposed will meet federal permit issuance standards is not relevant to whether the proposed project meets state WQC standards.

The third sub-issue was discussed in connection with the Intervenors' first proposed issue. As discussed above, since DEC is not the lead agency for this proposed project, allegations of omissions by the lead agency cannot be reviewed in a DEC permit hearing.

Ruling 3: None of these three sub-issues are substantive and significant; consequently, they are not advanced to adjudication. The Applicant cites no authority for their proposition that the WQC can only be issued after an ACOE permit. The question of whether the proposed project meets federal permitting standards is outside the scope of the DEC permit hearing process, as is the Intervenors' assertion that the lead agency did not properly consider impacts to wetlands.

INTERVENORS' PROPOSED ISSUE #4 - Adequacy of Stormwater Plans

The fourth and final issue proposed for adjudication by the Intervenors is the adequacy of the Applicant's Stormwater plans. In their petition, the Intervenors specifically identify two sub-issues, however, attached to the petition as Exhibit J was a five-page report by Ripple Engineering, Inc. ("the Ripple Report"), completed on April 20, 2000, which identified other sub-issues regarding the proposed project's stormwater plans. While the Intervenors only addressed the two sub-issues in their petition at the Issues Conference, both DEC Staff and the Applicant addressed some of the concerns raised in the Ripple Report. In the interest of completeness, all sub-issues are addressed below.

As discussed above, the proposed project would be subject to the conditions of two SPDES stormwater permits, one to regulate stormwater during construction and the second which would be effective during the operation of the project. During construction, stormwater discharges from the proposed project would be regulated by a General Permit, GP-93-06. This general permit requires the control of runoff during construction and contains requirements for post-development, including a requirement that applicants attenuate post-development peak flows to pre-development conditions for two, ten and hundred year storm events. Following construction of the proposed facility, a second, individual SPDES stormwater permit would be in force to regulate stormwater discharges from the proposed industrial facility.

Stormwater Sub-Issues Raised in the Petition

The first deficiency alleged by the Intervenors in their petition relates to a statement in the DEIS and FEIS that an analysis of a "one-hour 100 year storm" was conducted. According to the Intervenors, an analysis of a "24 hour 100 year return period storm" was required by the construction stormwater permit, GP-93-06. According to both the Applicant and DEC Staff, this statement in the DEIS and FEIS is merely a typographical error and that the required 24-hour storm was properly analyzed and all permit criteria were met. The Intervenors do not challenge the assertion that this is merely a typographic error and make no allegation or offer of proof that any necessary analysis has been omitted. Accordingly, this sub-issue is not adjudicable.

The second sub-issue raised by the Intervenors in their petition is that the analyses of pollutant loadings that the Applicant performed used an incorrect baseline which results in an incorrect assessment of the amount of phosphorus that would be released from the proposed project. Specifically, the Intervenors allege that the Applicant characterized the site, pre-development, as a tilled farm field when it should have been characterized as abandoned farmland or woodland. Because of this alleged mischaracterization, the Applicant estimated a baseline phosphorus load of 4.2 pounds per acre per year, instead of 0.2. By improperly increasing the existing phosphorus loading, the Intervenors allege that the Applicant has underestimated the impact of the proposed project. The Intervenors do not identify any standard or regulation that is violated by the alleged use of this incorrect benchmark, nor do they suggest an additional permit condition that could correct this problem, nor do they make any comment regarding the relative magnitude of this discrepancy or any possible environmental impacts.

The Applicant responds that the debate as to whether the correct benchmark was used is irrelevant because there are no standards relating to pollutant loadings of phosphorus. There are no specific criteria for effluent limits in GP-93-06 and there are standards in the SPDES stormwater permit in effect during operation for other pollutants, but not for phosphorus, nor is one required. A SPDES stormwater application does require a comparison of pre- and post-development runoff, which necessarily requires a characterization of pre-development conditions, but DEC Staff assert this is a highly subjective undertaking. The Intervenors have failed to raise a sufficient doubt about the Applicant's ability to meet an applicable regulatory criteria nor have they demonstrated how this information could result in permit denial. Because of this, the Intervenors have failed show that this proposed sub-issue is either substantive or significant.

Stormwater Sub-issues Mentioned in the Ripple Report

The Ripple Report is entitled "Review of the DEIS and FEIS for the Proposed Asphalt Plant, Town of Wallkill, Orange County, New York." As discussed above, since DEC is not the lead agency for this proposed project, SEQRA issues cannot be reviewed in the DEC permit hearing process. However, the Intervenors rely on the Ripple Report to attack aspects of the Applicant's stormwater control plans, as these plans are reflected in the DEC's draft stormwater permits. It should be noted that the Ripple Report was finalized before the DEC Draft permits were prepared and the Intervenors offered no additional expert analysis of the DEC draft permits. While not specifically included in their petition or raised by their representatives at the Issues Conference, the Ripple Report reviews other impacts of the proposed project on Stormwater Drainage and Stormwater Quality. In limiting their petition and Issues Conference presentation to only the two sub-issues discussed above, it appears that the Intervenors are not pursuing the additional comments found in the Ripple Report with respect to stormwater. However, both the Applicant and DEC Staff addressed other information contained in the Ripple Report and a discussion of these additional comments is appropriate.

The Ripple Report questions the effect of the proposed project on stormwater drainage and criticized the models used by the Applicant. At the issues conference, both the Applicant's expert and DEC Staff experts challenged the conclusions in the Ripple Report. The Applicant referred to analyses conducted by its experts that analyzed the stormwater drainage patterns on the site and surrounding areas. DEC Staff concurred with the Applicant that the analyses were accurate and complete. The Intervenors did not address this issue in their petition or attempt to refute the statements of the Applicant's and DEC Staff's experts at the Issues Conference.

The Ripple Report also comments on the Stormwater Quality analyses done by the Applicant's experts. Contained in this section is the issue regarding pre-development conditions and phosphorus loading, discussed above. The Ripple Report also challenges the Applicant's experts' estimates of the amount of Total Nitrogen ("TN") and Biological Oxygen Demand ("BOD") that would be found in the stormwater runoff from the project. The Intervenors did not raise this issue in their Petition nor discuss it at the Issues Conference. Based upon the Intervenors' failure to raise this issue, neither the Applicant nor DEC Staff directly addressed these issues.

Finally, the Ripple Report also comments on the efficacy of some of the stormwater control methods proposed in the FEIS, including the use of an oil/grit separator, sumps, and detention basins. Again, these comments were not raised as issues by the Intervenors in either their Petition or at the Issues Conference. Ruling 4: Neither of the two sub-issues raised by the Intervenors at the issues conference meet the standards for adjudication. The other sub-issues found in the Ripple Report are deemed not raised by the Intervenor in this proceeding. None of these sub-issues are advanced to adjudication.


The Applicant and DEC Staff are parties to the hearing pursuant to 6 NYCRR 624.5(a). A necessary element of a successful petition for party status by an intervenor is the identification of a substantive and significant issue (6 NYCRR 624.5(b)(2)(i)). In this case, as discussed above, the Intervenors have failed to identify such an issue. Accordingly on this basis, the Intervenors' petition for party status is denied. The Applicant also challenges the Intervenors' environmental interest, which is another necessary element for a successful petition. For the reasons that follow, I reject Applicant's alternative ground for denying the Intervenors' petition for party status.


In order to be granted party status, an intervenor must demonstrate that it has an environmental interest in the proceeding (6 NYCRR 624.5(b)(1)). In this case, Intervenors contend their specific environmental interest in this proceeding "stems from the overwhelmingly negative impacts the Applicant's proposal will have on the Petitioners' health, safety, properties and businesses" (Petition, p.2). More specifically, the petition asserts that the petitioners "live, work and own property and businesses within several hundred feet to the Applicant's proposed asphalt plant" and that the impact of the plant "will endanger and degrade Petitioners' health, safety and well-being and property and safety and well-being of their medical patients and business customers" (Petition, p. 1).

The Applicant contents that the Intervenors' environmental interest is insufficient to support party status. The Applicant argues that none of the Intervenors have shown that they would be specifically harmed by the issuance of the permits. Specifically, the Applicant asserts that Intervenors failed to show adequate environmental interest with respect to proposed issues #3 and #4, which relate to the WQC and to SPDES stormwater permits, because the Intervenors failed show that they would be negatively impacted by the issuance of these permits. The Applicant asserts that since none of the Intervenors own property near the wetlands or down-gradient from the site, they cannot have an environmental interest sufficient to be granted party status. In essence, the Applicant argues that unless the Intervenors can show that they would enjoy a benefit to their property from a particular decision by the Commissioner on a proposed issue, the Intervenors cannot demonstrate an adequate environmental interest to propose issues in a DEC permit hearing.

This is an interpretation of environmental interest that has never been endorsed by the DEC Commissioner. Traditionally, the threshold for demonstrating environmental interest is very low and challenges to an intervenor's environmental interest have rarely been sustained. Unlike the standard for standing in court, the threshold to establish standing in an administrative hearing, such as DEC permit hearings, is lower. The fact that the Intervenors all own property or businesses within a short distance from the site is sufficient to show environmental interest, as that term is used in Part 624.

Ruling 5: The Intervenors have shown an adequate environmental interest in the issuance of the draft permits and the Applicant's challenge is rejected.


This matter is remanded to DEC Staff for further processing of the permit applications.


Pursuant to 6 NYCRR 624.6(e) and (g), and 624.8(d), these rulings on party status and issues may be appealed in writing to the Commissioner.

Any appeals must be received at the office of the Commissioner no later than April 1, 2003, at the following address: Commissioner Erin M. Crotty, NYS Department of Environmental Conservation, 625 Broadway, Albany, New York 12233-1010. Any responses to such appeals are to be received by April 8, 2001, at the same address. The parties are to transmit copies of any appeals and replies to all persons on the service list at the same time and in the same manner as they are sent to the Commissioner.

Any request for an adjustment to the appeal schedule must be made to the Chief ALJ, at the Office of Hearings and Mediation Services address.

P. Nicholas Garlick
Administrative Law Judge

Albany, New York
March 20, 2003

To: Jonah Triebwasser, Esq.
Deputy Regional Attorney
NYSDEC, Region 3
21 South Putt Corners Road
New Paltz, NY 12561-1696

Rosemary Stack, Esq.
5110 Velasko Road
Suite 200
Syracuse, NY 13215

James Bacon, Esq.
169 Main Street
New Paltz, NY 12561

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