NY State Senate Bill 2025-S2053

Current Bill Status - In Senate Committee Environmental Conservation Committee

Introduced
- In Committee Assembly
- In Committee Senate
- On Floor Calendar Assembly
- On Floor Calendar Senate
- Passed Assembly
- Passed Senate
Delivered to Governor
Signed By Governor

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	Assembly Actions - Lowercase Senate Actions - UPPERCASE
Feb 03, 2025	print number 2053a
Feb 03, 2025	amend and recommit to environmental conservation
Jan 15, 2025	referred to environmental conservation

Bill Amendments

Original

A (Active)

co-Sponsors

2025-S2053 - Details

Current Committee:: Senate Environmental Conservation
Law Section:: Environmental Conservation Law
Laws Affected:: Amd §§23-2711 & 23-2715, En Con L; amd §81, Pub Lds L
Versions Introduced in 2023-2024 Legislative Session:: S7736

2025-S2053 - Summary

Relates to permits and financial security for reclamation for salt mining beneath a lake; requires such permits to be subject to environmental quality review procedures; requires financial security to cover any damages directly or indirectly resulting from salt mining activities beneath a lake, including, but not limited to, those resulting from collapse or water contamination.

2025-S2053 - Sponsor Memo

                                 
BILL NUMBER: S2053

SPONSOR: WEBB
 
TITLE OF BILL:

An act to amend the environmental conservation law and the public lands
law, in relation to permits and financial security for reclamation for
salt mining beneath a lake

 
PURPOSE:

Relates to permits and financial security for reclamation for salt
mining beneath a lake SUMMARY OF PROVISIONS:

Section 1 of the bill amends subdivisions 11 and 12 of section 23-2711
of the environmental conservation law and adds new subdivisions 11-a and
14 to add requirements to the permit renewal process for projects that
allow salt mining beneath a lake.

Section 2 amends subdivision 6 of section 23-2715 of the environmental
conservation law regarding the required financial security for reclama-
tion for projects that include salt mining beneath a lake.

Section 3 adds a new subdivision 3 to section 81 of the public lands law
that requires the duration of such permit, consent or lease from New
York State with respect to salt mining beneath a lake be tied to the
duration of the permit issued by the department of environmental conser-
vation pursuant to title 27 of article 23 of the environmental conserva-
tion law.

Section 4 adds a severability clause. Section 5 adds the effective date.

 
JUSTIFICATION:

In August of 2023, Cargill, Inc. began the process of putting up for
sale the Cayuga Salt Mine (CSM) it has operated for more than five (5)
decades beneath Cayuga Lake in Lansing, NY in Tompkins County, where it
operates on several thousand acres of land it leases from New York
State. While the Mine Safety and Health Administration has been able to
inspect the CSM operation for worker safety, the state Department of
Environmental Conservation (DEC) has not regularly inspected the mine
for issues related to protecting the Cayuga Lake ecosystem. Now, after
decades of mining by Cargill, Cayuga Lake is saltier than nearly all the
other Finger Lakes. Further, due to continued mining and geologic condi-
tions, without intervention from the DEC to require an environmental
review, the lake is at risk of becoming permanently more saline.

NYS public lands law authorizes the state Office of General Services
(OGS) to grant the use of state-owned lands for mining purposes, includ-
ing those lands found beneath lakes. Since the mid 1970s, OGS has
provided consent orders to the CSM owner, Cargill, to allow for salt
mining under Cayuga Lake. The most recent consent order in 2019 provided
that Cargill would be able to provide notice to OGS and then extend the
consent order for ten years. This was done without the performance of an
environmental impact statement (EIS) or environmental quality review
(SEAR) under the New York State Department of Environmental Conserva-
tion.


DEC is also responsible for providing additional permitting through the
Mined Land Reclamation Law, that includes reclamation and closure
requirements of mined lands. Past civil lawsuits challenging the contin-
uance of mining permits by the DEC have been dismissed. The assertions
made in these lawsuits centered on the lack of DEC oversight or the
requirement of an EIS on the mine in light of significant environmental
issues with the Retsof salt mine in Livingston County, which, in 1994,
collapsed and flooded, causing two sinkholes, significant subsidence
damage, wells going dry, and the salinization of a freshwater aquifer.
The geological similarities of these two mines has the communities
surrounding Cayuga lake and its watershed justifiably concerned about
the significant environmental and ecological risks of mine collapse.

Cayuga Lake and its watershed is the largest in the region spanning
seven (7) counties, covering 860 square miles with more than 140 streams
that flow into the lake. Cayuga Lake itself is surrounded by a multitude
of communities and supports a tourist economy seeking the natural beauty
of the lake and the opportunity to visit the many vineyards found along
the Cayuga Lake Wine Trail. An accident within the salt mine below Cayu-
ga Lake could have an immediate and severe impact, reducing the quality
of the drinking water of about 100,000 residents and endangering the
region's $3 billion, 60,000-employee food, wine and recreational tourism
economy.

Despite an EIS being fully warranted by the scope of the environmental
risk posed by salt mining under a lake, the DEC, has, for decades, not
required the owners of Cayuga Salt Mine to cooperate with an EIS proc-
ess, despite repeated requests to do so.This legislation would bolster
existing protections by explicitly requiring an environmental impact
statement for mining under a lake where there has not been one for the
preceding 20 years, as well as an updated reclamation plan along with
appropriate financial security to ensure the communities relying on
Cayuga Lake and its watershed are protected from potential harm.

 
LEGISLATIVE HISTORY:

New bill.

 
FISCAL IMPLICATIONS:

None to state.

 
EFFECTIVE DATE:
This act shall take effect on the thirtieth day provided that section 2
of the bill shall take effect on the ninetieth day. Effective immediate-
ly, the addition, amendment and or repeal of any rule or regulation
necessary for the implementation of this act on its effective date are
authorized to be made and completed on or before such effective date.

2025-S2053 - Bill Text download pdf

                             
                     S T A T E   O F   N E W   Y O R K
 ________________________________________________________________________
 
                                   2053
 
                        2025-2026 Regular Sessions
 
                             I N  S E N A T E
 
                             January 15, 2025
                                ___________
 
 Introduced by Sens. WEBB, MAY, HARCKHAM -- read twice and ordered print-
   ed, and when printed to be committed to the Committee on Environmental
   Conservation
 
 AN  ACT to amend the environmental conservation law and the public lands
   law, in relation to permits and financial security for reclamation for
   salt mining beneath a lake

   THE PEOPLE OF THE STATE OF NEW YORK, REPRESENTED IN SENATE AND  ASSEM-
 BLY, DO ENACT AS FOLLOWS:
 
   Section  1.  Subdivisions 11 and 12 of section 23-2711 of the environ-
 mental conservation law, as added by chapter 166 of the  laws  of  1991,
 are  amended  and  two new subdivisions 11-a and 14 are added to read as
 follows:
   11. Permits issued pursuant to this  title  shall  be  renewable.    A
 complete application for renewal shall contain the following:
   (a) completed application forms;
   (b) an updated mining plan map consistent with paragraph (a) of subdi-
 vision one of section 23-2713 of this title and including an identifica-
 tion of the area to be mined during the proposed permit term;
   (c)  a  description  of  any changes to the mined land-use plan, WHICH
 SHALL INCLUDE, WITH RESPECT TO A PERMIT FOR SALT MINING BENEATH A  LAKE,
 AN  UPDATED  RECLAMATION  PLAN  OF  SURFACE AND SUBSURFACE AFFECTED LAND
 ACCOUNTING FOR ANY DIFFERENCES IN CIRCUMSTANCES  SINCE  THE  RECLAMATION
 PLAN WAS LAST APPROVED BY THE DEPARTMENT; [and]
   (d)  an identification of reclamation accomplished during the existing
 permit term; AND
   (E) A THIRTY-YEAR MONITORING PLAN WITH RESPECT TO A  PERMIT  FOR  SALT
 MINING BENEATH A LAKE OF ALL AFFECTED LANDS, SURFACE AND SUBSURFACE.
   11-A.  NOTWITHSTANDING  ANY PROVISION OF THIS SECTION TO THE CONTRARY,
 WITH RESPECT TO SALT MINING BENEATH  A  LAKE  WHERE  NO    ENVIRONMENTAL
 IMPACT  STATEMENT HAS BEEN PREPARED PURSUANT TO THE ENVIRONMENTAL QUALI-
 TY    REVIEW    REQUIREMENTS   OF   ARTICLE EIGHT   OF THIS CHAPTER WITH
 
  EXPLANATION--Matter in ITALICS (underscored) is new; matter in brackets
                       [ ] is old law to be omitted.
                                                            LBD03813-01-5

 S. 2053                             2
 
 RESPECT TO SUCH MINING WITHIN THE PRECEDING  TWENTY  YEARS,  ANY  PERMIT
 RENEWAL APPLICATION SHALL:
   (A)  NOT  CONSTITUTE  A  MINOR  PROJECT  WITHIN THE MEANING OF ARTICLE
 SEVENTY OF THIS CHAPTER;
   (B) BE TREATED AS AN APPLICATION FOR A NEW PERMIT;
   (C) CONSTITUTE AN ACTION REQUIRING ENVIRONMENTAL QUALITY REVIEW PURSU-
 ANT TO ARTICLE EIGHT OF THIS CHAPTER; AND
   (D) BE DEEMED AN ACTION THAT IS LIKELY TO REQUIRE THE  PREPARATION  OF
 AN  ENVIRONMENTAL IMPACT STATEMENT PURSUANT TO SUBPARAGRAPH (I) OF PARA-
 GRAPH (C) OF SUBDIVISION TWO OF SECTION 8-0113 OF THIS CHAPTER.
   12. The procedure for transfer of a permit  issued  pursuant  to  this
 title  is  the  procedure  for  permit  modification pursuant to article
 seventy of this chapter; PROVIDED, HOWEVER, AND NOTWITHSTANDING SUBDIVI-
 SION THIRTEEN OF THIS SECTION OR ANY OTHER PROVISION OF THIS SECTION  TO
 THE CONTRARY, ANY TRANSFER OR MODIFICATION OF A PERMIT TO ENGAGE IN SALT
 MINING  ACTIVITIES  BENEATH A LAKE SHALL CONSTITUTE A MATERIAL MODIFICA-
 TION OF THE PERMIT AND, IF NO ENVIRONMENTAL IMPACT  STATEMENT  HAS  BEEN
 PREPARED  PURSUANT  TO  THE ENVIRONMENTAL QUALITY REVIEW REQUIREMENTS OF
 ARTICLE EIGHT OF THIS CHAPTER WITH RESPECT TO  SUCH  MINING  WITHIN  THE
 PRECEDING TWENTY YEARS, SUCH TRANSFER OR MODIFICATION SHALL:
   (A)  NOT  CONSTITUTE  A  MINOR  PROJECT  WITHIN THE MEANING OF ARTICLE
 SEVENTY OF THIS CHAPTER;
   (B) BE TREATED AS AN APPLICATION FOR A NEW PERMIT;
   (C) CONSTITUTE AN ACTION REQUIRING ENVIRONMENTAL QUALITY REVIEW PURSU-
 ANT TO ARTICLE EIGHT OF THIS CHAPTER; AND
   (D)  BE DEEMED  AN ACTION THAT IS LIKELY TO REQUIRE THE PREPARATION OF
 AN ENVIRONMENTAL IMPACT STATEMENT PURSUANT TO SUBPARAGRAPH (I) OF  PARA-
 GRAPH (C) OF SUBDIVISION TWO OF SECTION 8-0113 OF THIS CHAPTER.
   14.  AS SOON AS PRACTICABLE AND IN ANY EVENT WITHIN ONE HUNDRED EIGHTY
 DAYS OF THE EFFECTIVE DATE OF THIS  SUBDIVISION,  THE  DEPARTMENT  SHALL
 PREPARE AN ENVIRONMENTAL STUDY WITH RESPECT TO ANY SALT MINING BENEATH A
 LAKE  IF  NO ENVIRONMENTAL IMPACT STATEMENT HAS BEEN PREPARED WITHIN THE
 PRECEDING TWENTY YEARS WITH RESPECT TO SUCH MINING.   ANY  HOLDER  OF  A
 PERMIT  TO  MINE  SALT  BENEATH  A LAKE SHALL COMPLY WITH ALL REASONABLE
 REQUESTS OF THE DEPARTMENT IN CONNECTION WITH  PREPARATION  OF  SUCH  AN
 ENVIRONMENTAL  STUDY.  THE PREPARATION OF SUCH ENVIRONMENTAL STUDY SHALL
 INCLUDE A  COMPREHENSIVE  REVIEW  OF  THE  CUMULATIVE  EFFECTS  OF  SUCH
 MINING,  INCLUDING CONSIDERATION OF THE EFFECTS OF PAST MINING AND THEIR
 POTENTIAL FUTURE ENVIRONMENTAL IMPACTS, IN THE SHORT-TERM AND THE  LONG-
 TERM;  ANY  ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED SHOULD
 THE MINING CONTINUE; ALTERNATIVES TO THE  CONTINUATION  OF  MINING;  ANY
 IRREVERSIBLE  AND  IRRETRIEVABLE COMMITMENTS OF RESOURCES WHICH WOULD BE
 INVOLVED IN THE CONTINUED OPERATION;  MITIGATION  MEASURES  PROPOSED  TO
 MINIMIZE  THE  ENVIRONMENTAL  IMPACT;  THE PRESENT AND FUTURE EFFECTS OF
 CONTINUED ACTION ON PUBLIC DRINKING  WATER  SUPPLIES;  THE  PRESENT  AND
 FUTURE  EFFECTS OF CONTINUED ACTION ON THE RECREATIONAL USE AND ECONOMIC
 ACTIVITY SUPPORTED BY THE LAKE, AND SUCH  OTHER  INFORMATION  CONSISTENT
 WITH  THE PURPOSE OF THIS SUBDIVISION AS MAY BE APPROPRIATE. IN CONDUCT-
 ING SUCH STUDY, THE DEPARTMENT SHALL ENGAGE IN A ROBUST  PUBLIC  PARTIC-
 IPATION  PROCESS  TO  ENSURE  THAT  THE CONCERNS OF ALL STAKEHOLDERS ARE
 HEARD AND INFORM THE FINAL STUDY. THE  INITIAL  FINDINGS  OF  THE  STUDY
 SHALL  BE  MADE  AVAILABLE  TO THE PUBLIC ON THE DEPARTMENT'S WEBSITE NO
 LATER THAN ONE HUNDRED TWENTY DAYS AFTER  THE  EFFECTIVE  DATE  OF  THIS
 SUBDIVISION, AND SHALL BE SUBJECT TO A THIRTY DAY PUBLIC COMMENT PERIOD.
 THE  DEPARTMENT  SHALL  CONDUCT  AT  LEAST ONE PUBLIC HEARING DURING THE
 THIRTY DAY COMMENT PERIOD FOR REVIEW OF THE INITIAL FINDINGS.  THE FINAL
 S. 2053                             3
 
 STUDY  SHALL  RESPOND  TO  AND,  IF  APPROPRIATE,  INCORPORATE  COMMENTS
 RECEIVED  FROM  THE  PUBLIC  AND  BE MADE AVAILABLE TO THE PUBLIC ON THE
 DEPARTMENT'S WEBSITE IN UNREDACTED FORM.
   § 2. Section 23-2715 of the environmental conservation law, as amended
 by  chapter 166 of the laws of 1991, subdivision 6 as amended by chapter
 60 of the laws of 1993, is amended to read as follows:
 § 23-2715. Financial security for reclamation.
   1. Before the department may issue a  permit,  the  applicant,  unless
 exempt,  shall  furnish financial security (A) to ensure the performance
 of reclamation as provided in the approved mined land-use plan,  (B)  TO
 COVER  ANY  DAMAGES  DIRECTLY  OR  INDIRECTLY RESULTING FROM SALT MINING
 ACTIVITIES BENEATH A LAKE, INCLUDING, BUT NOT LIMITED TO, THOSE  RESULT-
 ING  FROM  COLLAPSE  OR WATER CONTAMINATION, and (C) naming the state as
 beneficiary. Financial security shall be in the form of a  bond  from  a
 corporate  surety  licensed  to  do business as such in the state or any
 other form the department may deem acceptable. Any interest accruing  as
 a result of such security shall be the exclusive property of the permit-
 tee.
   2.  The department shall determine the amount, condition, and terms of
 the financial security. The amount shall be  based  upon  the  estimated
 cost  of  reclaiming  the affected land AND THE ESTIMATED LIABILITY FROM
 POTENTIAL DAMAGES DIRECTLY OR  INDIRECTLY  RESULTING  FROM  SALT  MINING
 ACTIVITIES  BENEATH A LAKE, INCLUDING, BUT NOT LIMITED TO, THOSE RESULT-
 ING FROM COLLAPSE OR WATER CONTAMINATION, which shall be based on infor-
 mation contained in the permit application,  THE  ENVIRONMENTAL  QUALITY
 REVIEW CONDUCTED PURSUANT TO ARTICLE EIGHT OF THIS CHAPTER AND ANY ENVI-
 RONMENTAL  STUDY  CONDUCTED  PURSUANT TO SUBDIVISION FOURTEEN OF SECTION
 23-2711 OF THIS TITLE and upon such information as an  investigation  by
 the department may disclose. AT A MINIMUM, THE DEPARTMENT SHALL CONSIDER
 THE PARTICULAR CIRCUMSTANCES OF THE MINE AND MINING ACTIVITIES IN MAKING
 DETERMINATIONS PURSUANT TO THIS SUBDIVISION RELATED TO FINANCIAL SECURI-
 TY  AMOUNTS  REQUIRED  TO COVER POTENTIAL DAMAGES DIRECTLY OR INDIRECTLY
 RESULTING FROM SALT MINING ACTIVITIES BENEATH A LAKE, INCLUDING, BUT NOT
 LIMITED TO,  THOSE  RESULTING  FROM  COLLAPSE  OR  WATER  CONTAMINATION.
 CONSIDERATION  IN  SUCH  CIRCUMSTANCES SHALL INCLUDE, BUT NOT BE LIMITED
 TO:
   (A) THOSE FACTORS CONSIDERED IN DETERMINING THE  AMOUNT  OF  FINANCIAL
 SECURITY TO ENSURE PERFORMANCE OF RECLAMATION;
   (B) GEOLOGIC, HYDROLOGIC, AND OTHER ENVIRONMENTAL CONDITIONS;
   (C) THE PRESENCE OF ANY ENVIRONMENTALLY SENSITIVE AREAS OR RESOURCES;
   (D) THE PRESENCE OF PERSONS AND PROPERTY; AND
   (E) LOCAL ECONOMIC IMPACTS OF POTENTIAL DAMAGES.
   THE DEPARTMENT SHALL ENGAGE AN INDEPENDENT THIRD PARTY WITH THE NECES-
 SARY  ACTUARIAL, CONSERVATION FINANCE AND/OR OTHER APPROPRIATE EXPERTISE
 EITHER TO MAKE A DETERMINATION WITH RESPECT TO  SUCH  POTENTIAL  DAMAGES
 DIRECTLY  OR    INDIRECTLY   RESULTING   FROM   SALT   MINING ACTIVITIES
 BENEATH A LAKE OR TO REVIEW THE DETERMINATION  OF  THE  DEPARTMENT  WITH
 RESPECT  THERETO  AND,  IN  THE  CASE  OF A REVIEW, THE DEPARTMENT SHALL
 INCORPORATE THE APPROPRIATE RECOMMENDATIONS BY SUCH  INDEPENDENT  THIRD-
 PARTY REVIEWER INTO ITS FINAL DETERMINATION.
   3.  The financial security shall remain in full force and effect until
 the department has approved the reclamation AND DETERMINED THAT THERE IS
 NO CONTINUING RISK OF DAMAGES DIRECTLY OR INDIRECTLY  FROM  SALT  MINING
 ACTIVITIES  BENEATH A LAKE, INCLUDING, BUT NOT LIMITED TO, THOSE RESULT-
 ING FROM COLLAPSE OR WATER  CONTAMINATION.  At  the  discretion  of  the
 department,  the permittee may secure the release of that portion of the
 S. 2053                             4

 financial security for affected  land  on  which  reclamation  has  been
 completed and approved by the department.
   4. If the financial security shall for any reason be cancelled, within
 thirty  days after receiving notice thereof, the permittee shall provide
 a valid replacement under the  same  conditions  as  described  in  this
 section.  Failure  to provide a replacement bond within such period may,
 at the discretion of the commissioner, result in the  immediate  suspen-
 sion of the mining permit by the department.
   5. If a permit is suspended or revoked, the department may require the
 permittee to commence reclamation upon thirty days notice.
   6.  If  the permittee fails to commence or to complete the reclamation
 as required, the department may attach the financial security  furnished
 by  the permittee. In any event, the full cost of completing reclamation
 AND ANY DAMAGES DIRECTLY OR INDIRECTLY RESULTING FROM SALT MINING ACTIV-
 ITIES BENEATH A LAKE, INCLUDING, BUT NOT  LIMITED  TO,  THOSE  RESULTING
 FROM  COLLAPSE OR WATER CONTAMINATION shall be the personal liability of
 the permittee and/or the person engaged in mining  and  the  department,
 acting  by  the attorney general, may bring suit to recover all costs to
 secure the reclamation AND DAMAGES DIRECTLY OR INDIRECTLY RESULTING FROM
 SALT MINING ACTIVITIES BENEATH A LAKE not covered by the financial secu-
 rity.  The  materials,  machinery,  implements  and   tools   of   every
 description  which  may  be  found  at  the mine, or other assets of the
 permittee and/or the person engaged in mining shall be subject to a lien
 of the department for the amount expended for  reclamation  of  affected
 lands,  AND  FOR MAKING WHOLE ANY PARTIES SUFFERING ANY DAMAGES DIRECTLY
 OR INDIRECTLY RESULTING FROM SALT MINING ACTIVITIES BENEATH A LAKE,  and
 shall not be removed without the written consent of the department. Such
 lien  may  be foreclosed by the attorney general in the same manner as a
 mechanic's lien. Any and all moneys recovered shall be deposited in  the
 environmental  regulatory  account  pursuant  to section 72-1009 of this
 chapter.
   7. Political subdivisions, municipalities, the United States  and  any
 of  its  agencies  and  agencies  of  the state shall be exempt from the
 requirements of this section.
   8. ANY PERMITTEE WHICH HAS FURNISHED A FINANCIAL SECURITY WHICH IS NOT
 IN COMPLIANCE WITH THE REQUIREMENTS OF THIS  SECTION  ON  THE  EFFECTIVE
 DATE  OF  THIS SUBDIVISION SHALL BE IN VIOLATION OF THIS SECTION IF SUCH
 FINANCIAL SECURITY IS NOT BROUGHT INTO COMPLIANCE WITHIN SIX  MONTHS  OF
 SUCH EFFECTIVE DATE.
   §  3.    Section 81 of the public lands law is amended by adding a new
 subdivision 3 to read as follows:
   3. NOTWITHSTANDING SUBDIVISIONS ONE AND  TWO  OF  THIS  SECTION,  WITH
 RESPECT  TO  A  PERMIT,  CONSENT,  OR  LEASE ISSUED WITH RESPECT TO SALT
 MINING ACTIVITIES BENEATH A LAKE, THE DURATION OF SUCH PERMIT,  CONSENT,
 OR  LEASE  SHALL  NOT  BE  LONGER  THAN THE DURATION FOR WHICH MINING IS
 ALLOWABLE UNDER THE PERMIT ISSUED BY  THE  DEPARTMENT  OF  ENVIRONMENTAL
 CONSERVATION  PURSUANT  TO TITLE TWENTY-SEVEN OF ARTICLE TWENTY-THREE OF
 THE ENVIRONMENTAL CONSERVATION LAW IN RESPECT OF SUCH MINING.
   § 4. Severability. If any provision of this act, or any application of
 any provision of this act, is held to be invalid, that shall not  affect
 the  validity or effectiveness of any other provision of this act, or of
 any other application of any provision of this act, which can  be  given
 effect  without  that  provision  or  application;  and to that end, the
 provisions and applications of this act are severable.
   § 5. This act shall take effect on the thirtieth day  after  it  shall
 have become a law; provided, however, that section two of this act shall
 S. 2053                             5
 
 take  effect  on  the  ninetieth  day  after it shall have become a law.
 Effective immediately, the addition, amendment and/or repeal   of    any
 rule    or regulation necessary   for  the implementation of this act on
 its  effective date are authorized to be made and completed on or before
 such effective date.

co-Sponsors

2025-S2053A (ACTIVE) - Details

Current Committee:: Senate Environmental Conservation
Law Section:: Environmental Conservation Law
Laws Affected:: Amd §§23-2711 & 23-2715, En Con L; amd §81, Pub Lds L
Versions Introduced in 2023-2024 Legislative Session:: S7736

2025-S2053A (ACTIVE) - Summary

2025-S2053A (ACTIVE) - Sponsor Memo

                                 
BILL NUMBER: S2053A

SPONSOR: WEBB
 
TITLE OF BILL:

An act to amend the environmental conservation law and the public lands
law, in relation to permits and financial security for reclamation for
salt mining beneath a lake

 
PURPOSE:

Relates to permits and financial security for reclamation for salt
mining beneath a lake SUMMARY OF PROVISIONS:

Section 1 of the bill amends subdivisions 11 and 12 of section 23-2711
of the environmental conservation law and adds new subdivisions 11-a and
14 to add requirements to the permit renewal process for projects that
allow salt mining beneath a lake.

Section 2 amends subdivision 6 of section 23-2715 of the environmental
conservation law regarding the required financial security for reclama-
tion for projects that include salt mining beneath a lake.

Section 3 adds a new subdivision 3 to section 81 of the public lands law
that requires the duration of such permit, consent or lease from New
York State with respect to salt mining beneath a take be tied to the
duration of the permit issued by the department of environmental conser-
vation pursuant to title 27 of article 23 of the environmental conserva-
tion law.

Section 4 adds a severability clause. Section 5 adds the effective date.

 
JUSTIFICATION:

In August of 2023, Cargill, Inc. began the process of putting up for
sale the Cayuga Salt Mine (CSM) it has operated for more than five (5)
decades beneath Cayuga Lake in Lansing, NY in Tompkins County, where it
operates on several thousand acres of land it leases from New York
State. While the Mine Safety and Health Administration has been able to
inspect the CSM operation for worker safety, the state Department of
Environmental Conservation (DEC) has not regularly inspected the mine
for issues related to protecting the Cayuga Lake ecosystem. Now, after
decades of mining by Cargill, Cayuga Lake is saltier than nearly all the
other Finger Lakes. Further, due to continued mining and geologic condi-
tions, without intervention from the DEC to require an environmental
review, the lake is at risk of becoming permanently more saline.

NYS public lands law authorizes the state Office of General Services
(OGS) to grant the use of state-owned lands for mining purposes, includ-
ing those lands found beneath takes. Since the mid 1970s, OGS has
provided consent orders to the CSM owner, Cargill, to allow for salt
mining under Cayuga Lake. The most recent consent order in 2019 provided
that Cargill would be able to provide notice to OGS and then extend the
consent order for ten years. This was done without the performance of an
environmental impact statement (EIS) or environmental quality review
(SEAR) under the New York State Department of Environmental Conserva-
tion.


DEC is also responsible for providing additional permitting through the
Mined Land Reclamation Law, that includes reclamation and closure
requirements of mined lands. Past civil lawsuits challenging the contin-
uance of mining permits by the DEC have been dismissed. The assertions
made in these lawsuits centered on the tack of DEC oversight or the
requirement of an EIS on the mine in light of significant environmental
issues with the Retsof salt mine in Livingston County, which, in 1994,
collapsed and flooded, causing two sinkholes, significant subsidence
damage, wells going dry, and the salinization of a freshwater aquifer.
The geological similarities of these two mines has the communities
surrounding Cayuga lake and its watershed justifiably concerned about
the significant environmental and ecological risks of mine collapse.

Cayuga Lake and its watershed is the largest in the region spanning
seven (7) counties, covering 860 square mites with more than 140 streams
that flow into the lake. Cayuga Lake itself is surrounded by a multitude
of communities and supports a tourist economy seeking the natural beauty
of the take and the opportunity to visit the many vineyards found along
the Cayuga Lake Wine Trail. An accident within the salt mine below Cayu-
ga Lake could have an immediate and severe impact, reducing the quality
of the drinking water of about 100,000 residents and endangering the
region's $3 billion, 60,000-employee food, wine and recreational tourism
economy.

Despite an EIS being fully warranted by the scope of the environmental
risk posed by salt mining under a lake, the DEC, has, for decades, not
required the owners of Cayuga Salt Mine to cooperate with an EIS proc-
ess, despite repeated requests to do so.This legislation would bolster
existing protections by explicitly requiring an environmental impact
statement for mining under a lake where there has not been one for the
preceding 20 years, as well as an updated reclamation plan along with
appropriate financial security to ensure the communities relying on
Cayuga Lake and its watershed are protected from potential harm.

 
LEGISLATIVE HISTORY:

06/07/24 PASSED SENATE

06/07/24 DELIVERED TO ASSEMBLY

06/07/24 referred to environmental conservation

 
FISCAL IMPLICATIONS:

None to state.

 
EFFECTIVE DATE:
This act shall take effect on the thirtieth day provided that section 2
of the bill shalt take effect on the ninetieth day. Effective immediate-
ly, the addition, amendment and or repeal of any rule or regulation
necessary for the implementation of this act on its effective date are
authorized to be made and completed on or before such effective date.

2025-S2053A (ACTIVE) - Bill Text download pdf

                             
                     S T A T E   O F   N E W   Y O R K
 ________________________________________________________________________
 
                                  2053--A
 
                        2025-2026 Regular Sessions
 
                             I N  S E N A T E
 
                             January 15, 2025
                                ___________
 
 Introduced by Sens. WEBB, MAY, HARCKHAM -- read twice and ordered print-
   ed, and when printed to be committed to the Committee on Environmental
   Conservation  -- committee discharged, bill amended, ordered reprinted
   as amended and recommitted to said committee
 
 AN ACT to amend the environmental conservation law and the public  lands
   law, in relation to permits and financial security for reclamation for
   salt mining beneath a lake
 
   THE  PEOPLE OF THE STATE OF NEW YORK, REPRESENTED IN SENATE AND ASSEM-
 BLY, DO ENACT AS FOLLOWS:
 
   Section 1. Subdivisions 11 and 12 of section 23-2711 of  the  environ-
 mental  conservation  law,  as added by chapter 166 of the laws of 1991,
 are amended and two new subdivisions 11-a and 14 are added  to  read  as
 follows:
   11.  Permits  issued  pursuant  to  this title shall be renewable.   A
 complete application for renewal shall contain the following:
   (a) completed application forms;
   (b) an updated mining plan map consistent with paragraph (a) of subdi-
 vision one of section 23-2713 of this title and including an identifica-
 tion of the area to be mined during the proposed permit term;
   (c) a description of any changes to the  mined  land-use  plan,  WHICH
 SHALL  INCLUDE, WITH RESPECT TO A PERMIT FOR SALT MINING BENEATH A LAKE,
 AN UPDATED RECLAMATION PLAN OF  SURFACE  AND  SUBSURFACE  AFFECTED  LAND
 ACCOUNTING  FOR  ANY  DIFFERENCES IN CIRCUMSTANCES SINCE THE RECLAMATION
 PLAN WAS LAST APPROVED BY THE DEPARTMENT; [and]
   (d) an identification of reclamation accomplished during the  existing
 permit term; AND
   (E)  A  THIRTY-YEAR  MONITORING PLAN WITH RESPECT TO A PERMIT FOR SALT
 MINING BENEATH A LAKE OF ALL AFFECTED LANDS, SURFACE AND SUBSURFACE.
   11-A. NOTWITHSTANDING ANY PROVISION OF THIS SECTION TO  THE  CONTRARY,
 WITH  RESPECT  TO  SALT  MINING  BENEATH A LAKE WHERE NO   ENVIRONMENTAL
 IMPACT  STATEMENT HAS BEEN PREPARED PURSUANT TO THE ENVIRONMENTAL QUALI-
 
  EXPLANATION--Matter in ITALICS (underscored) is new; matter in brackets
                       [ ] is old law to be omitted.
                                                            LBD03813-03-5

 S. 2053--A                          2
 
 TY   REVIEW   REQUIREMENTS   OF   ARTICLE EIGHT   OF THIS  CHAPTER  WITH
 RESPECT  TO  SUCH  MINING  WITHIN THE PRECEDING TWENTY YEARS, ANY PERMIT
 RENEWAL APPLICATION SHALL:
   (A)  NOT  CONSTITUTE  A  MINOR  PROJECT  WITHIN THE MEANING OF ARTICLE
 SEVENTY OF THIS CHAPTER;
   (B) BE TREATED AS AN APPLICATION FOR A NEW PERMIT;
   (C) CONSTITUTE AN ACTION REQUIRING ENVIRONMENTAL QUALITY REVIEW PURSU-
 ANT TO ARTICLE EIGHT OF THIS CHAPTER; AND
   (D) BE DEEMED AN ACTION THAT IS LIKELY TO REQUIRE THE  PREPARATION  OF
 AN  ENVIRONMENTAL IMPACT STATEMENT PURSUANT TO SUBPARAGRAPH (I) OF PARA-
 GRAPH (C) OF SUBDIVISION TWO OF SECTION 8-0113 OF THIS CHAPTER.
   12. The procedure for transfer of a permit  issued  pursuant  to  this
 title  is  the  procedure  for  permit  modification pursuant to article
 seventy of this chapter; PROVIDED, HOWEVER, AND NOTWITHSTANDING SUBDIVI-
 SION THIRTEEN OF THIS SECTION OR ANY OTHER PROVISION OF THIS SECTION  TO
 THE CONTRARY, ANY TRANSFER OR MODIFICATION OF A PERMIT TO ENGAGE IN SALT
 MINING  ACTIVITIES  BENEATH A LAKE SHALL CONSTITUTE A MATERIAL MODIFICA-
 TION OF THE PERMIT AND, IF NO ENVIRONMENTAL IMPACT  STATEMENT  HAS  BEEN
 PREPARED  PURSUANT  TO  THE ENVIRONMENTAL QUALITY REVIEW REQUIREMENTS OF
 ARTICLE EIGHT OF THIS CHAPTER WITH RESPECT TO  SUCH  MINING  WITHIN  THE
 PRECEDING TWENTY YEARS, SUCH TRANSFER OR MODIFICATION SHALL:
   (A)  NOT  CONSTITUTE  A  MINOR  PROJECT  WITHIN THE MEANING OF ARTICLE
 SEVENTY OF THIS CHAPTER;
   (B) BE TREATED AS AN APPLICATION FOR A NEW PERMIT;
   (C) CONSTITUTE AN ACTION REQUIRING ENVIRONMENTAL QUALITY REVIEW PURSU-
 ANT TO ARTICLE EIGHT OF THIS CHAPTER; AND
   (D)  BE DEEMED  AN ACTION THAT IS LIKELY TO REQUIRE THE PREPARATION OF
 AN ENVIRONMENTAL IMPACT STATEMENT PURSUANT TO SUBPARAGRAPH (I) OF  PARA-
 GRAPH (C) OF SUBDIVISION TWO OF SECTION 8-0113 OF THIS CHAPTER.
   14.  AS SOON AS PRACTICABLE AND IN ANY EVENT WITHIN ONE HUNDRED EIGHTY
 DAYS OF THE EFFECTIVE DATE OF THIS  SUBDIVISION,  THE  DEPARTMENT  SHALL
 PREPARE AN ENVIRONMENTAL STUDY WITH RESPECT TO ANY SALT MINING BENEATH A
 LAKE  IF  NO ENVIRONMENTAL IMPACT STATEMENT HAS BEEN PREPARED WITHIN THE
 PRECEDING TWENTY YEARS WITH RESPECT TO SUCH MINING.   ANY  HOLDER  OF  A
 PERMIT  TO  MINE  SALT  BENEATH  A LAKE SHALL COMPLY WITH ALL REASONABLE
 REQUESTS OF THE DEPARTMENT IN CONNECTION WITH  PREPARATION  OF  SUCH  AN
 ENVIRONMENTAL  STUDY.  THE PREPARATION OF SUCH ENVIRONMENTAL STUDY SHALL
 INCLUDE A  COMPREHENSIVE  REVIEW  OF  THE  CUMULATIVE  EFFECTS  OF  SUCH
 MINING,  INCLUDING CONSIDERATION OF THE EFFECTS OF PAST MINING AND THEIR
 POTENTIAL FUTURE ENVIRONMENTAL IMPACTS, IN THE SHORT-TERM AND THE  LONG-
 TERM;  ANY  ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED SHOULD
 THE MINING CONTINUE; ALTERNATIVES TO THE  CONTINUATION  OF  MINING;  ANY
 IRREVERSIBLE  AND  IRRETRIEVABLE COMMITMENTS OF RESOURCES WHICH WOULD BE
 INVOLVED IN THE CONTINUED OPERATION;  MITIGATION  MEASURES  PROPOSED  TO
 MINIMIZE  THE  ENVIRONMENTAL  IMPACT;  THE PRESENT AND FUTURE EFFECTS OF
 CONTINUED ACTION ON PUBLIC DRINKING  WATER  SUPPLIES;  THE  PRESENT  AND
 FUTURE  EFFECTS OF CONTINUED ACTION ON THE RECREATIONAL USE AND ECONOMIC
 ACTIVITY SUPPORTED BY THE LAKE, AND SUCH  OTHER  INFORMATION  CONSISTENT
 WITH  THE PURPOSE OF THIS SUBDIVISION AS MAY BE APPROPRIATE. IN CONDUCT-
 ING SUCH STUDY, THE DEPARTMENT SHALL ENGAGE IN A ROBUST  PUBLIC  PARTIC-
 IPATION  PROCESS  TO  ENSURE  THAT  THE CONCERNS OF ALL STAKEHOLDERS ARE
 HEARD AND INFORM THE FINAL STUDY. THE  INITIAL  FINDINGS  OF  THE  STUDY
 SHALL  BE  MADE  AVAILABLE  TO THE PUBLIC ON THE DEPARTMENT'S WEBSITE NO
 LATER THAN ONE HUNDRED TWENTY DAYS AFTER  THE  EFFECTIVE  DATE  OF  THIS
 SUBDIVISION, AND SHALL BE SUBJECT TO A THIRTY DAY PUBLIC COMMENT PERIOD.
 THE  DEPARTMENT  SHALL  CONDUCT  AT  LEAST ONE PUBLIC HEARING DURING THE
 S. 2053--A                          3
 
 THIRTY DAY COMMENT PERIOD FOR REVIEW OF THE INITIAL FINDINGS.  THE FINAL
 STUDY  SHALL  RESPOND  TO  AND,  IF  APPROPRIATE,  INCORPORATE  COMMENTS
 RECEIVED  FROM  THE  PUBLIC  AND  BE MADE AVAILABLE TO THE PUBLIC ON THE
 DEPARTMENT'S WEBSITE IN UNREDACTED FORM.
   § 2. Section 23-2715 of the environmental conservation law, as amended
 by  chapter 166 of the laws of 1991, subdivision 6 as amended by chapter
 60 of the laws of 1993, is amended to read as follows:
 § 23-2715. Financial security for reclamation.
   1. Before the department may issue a  permit,  the  applicant,  unless
 exempt,  shall  furnish financial security (A) to ensure the performance
 of reclamation as provided in the approved mined land-use plan,  (B)  TO
 COVER  ANY  DAMAGES  DIRECTLY  OR  INDIRECTLY RESULTING FROM SALT MINING
 ACTIVITIES BENEATH A LAKE, INCLUDING, BUT NOT LIMITED TO, THOSE  RESULT-
 ING  FROM  COLLAPSE  OR WATER CONTAMINATION, and (C) naming the state as
 beneficiary. Financial security shall be in the form of a  bond  from  a
 corporate  surety  licensed  to  do business as such in the state or any
 other form the department may deem acceptable. Any interest accruing  as
 a result of such security shall be the exclusive property of the permit-
 tee.
   2.  The department shall determine the amount, condition, and terms of
 the financial security. The amount shall be  based  upon  the  estimated
 cost  of  reclaiming  the affected land AND THE ESTIMATED LIABILITY FROM
 POTENTIAL DAMAGES DIRECTLY OR  INDIRECTLY  RESULTING  FROM  SALT  MINING
 ACTIVITIES  BENEATH A LAKE, INCLUDING, BUT NOT LIMITED TO, THOSE RESULT-
 ING FROM COLLAPSE OR WATER CONTAMINATION, which shall be based on infor-
 mation contained in the permit application,  THE  ENVIRONMENTAL  QUALITY
 REVIEW CONDUCTED PURSUANT TO ARTICLE EIGHT OF THIS CHAPTER AND ANY ENVI-
 RONMENTAL  STUDY  CONDUCTED  PURSUANT TO SUBDIVISION FOURTEEN OF SECTION
 23-2711 OF THIS TITLE and upon such information as an  investigation  by
 the department may disclose. AT A MINIMUM, THE DEPARTMENT SHALL CONSIDER
 THE PARTICULAR CIRCUMSTANCES OF THE MINE AND MINING ACTIVITIES IN MAKING
 DETERMINATIONS PURSUANT TO THIS SUBDIVISION RELATED TO FINANCIAL SECURI-
 TY  AMOUNTS  REQUIRED  TO COVER POTENTIAL DAMAGES DIRECTLY OR INDIRECTLY
 RESULTING FROM SALT MINING ACTIVITIES BENEATH A LAKE, INCLUDING, BUT NOT
 LIMITED TO,  THOSE  RESULTING  FROM  COLLAPSE  OR  WATER  CONTAMINATION.
 CONSIDERATION  IN  SUCH  CIRCUMSTANCES SHALL INCLUDE, BUT NOT BE LIMITED
 TO:
   (A) THOSE FACTORS CONSIDERED IN DETERMINING THE  AMOUNT  OF  FINANCIAL
 SECURITY TO ENSURE PERFORMANCE OF RECLAMATION;
   (B) GEOLOGIC, HYDROLOGIC, AND OTHER ENVIRONMENTAL CONDITIONS;
   (C) THE PRESENCE OF ANY ENVIRONMENTALLY SENSITIVE AREAS OR RESOURCES;
   (D) THE PRESENCE OF PERSONS AND PROPERTY; AND
   (E) LOCAL ECONOMIC IMPACTS OF POTENTIAL DAMAGES.
   THE DEPARTMENT SHALL ENGAGE AN INDEPENDENT THIRD PARTY WITH THE NECES-
 SARY  ACTUARIAL, CONSERVATION FINANCE AND/OR OTHER APPROPRIATE EXPERTISE
 EITHER TO MAKE A DETERMINATION WITH RESPECT TO  SUCH  POTENTIAL  DAMAGES
 DIRECTLY  OR    INDIRECTLY   RESULTING   FROM   SALT   MINING ACTIVITIES
 BENEATH A LAKE OR TO REVIEW THE DETERMINATION  OF  THE  DEPARTMENT  WITH
 RESPECT  THERETO  AND,  IN  THE  CASE  OF A REVIEW, THE DEPARTMENT SHALL
 INCORPORATE THE APPROPRIATE RECOMMENDATIONS BY SUCH  INDEPENDENT  THIRD-
 PARTY REVIEWER INTO ITS FINAL DETERMINATION.
   3.  The financial security shall remain in full force and effect until
 the department has approved the reclamation AND DETERMINED THAT THERE IS
 NO CONTINUING RISK OF DAMAGES DIRECTLY OR INDIRECTLY  FROM  SALT  MINING
 ACTIVITIES  BENEATH A LAKE, INCLUDING, BUT NOT LIMITED TO, THOSE RESULT-
 ING FROM COLLAPSE OR WATER  CONTAMINATION.  At  the  discretion  of  the
 S. 2053--A                          4
 
 department,  the permittee may secure the release of that portion of the
 financial security for affected  land  on  which  reclamation  has  been
 completed and approved by the department.
   4. If the financial security shall for any reason be cancelled, within
 thirty  days after receiving notice thereof, the permittee shall provide
 a valid replacement under the  same  conditions  as  described  in  this
 section.  Failure  to provide a replacement bond within such period may,
 at the discretion of the commissioner, result in the  immediate  suspen-
 sion of the mining permit by the department.
   5. If a permit is suspended or revoked, the department may require the
 permittee to commence reclamation upon thirty days notice.
   6.  If  the permittee fails to commence or to complete the reclamation
 as required, the department may attach the financial security  furnished
 by  the permittee. In any event, the full cost of completing reclamation
 AND ANY DAMAGES DIRECTLY OR INDIRECTLY RESULTING FROM SALT MINING ACTIV-
 ITIES BENEATH A LAKE, INCLUDING, BUT NOT  LIMITED  TO,  THOSE  RESULTING
 FROM  COLLAPSE OR WATER CONTAMINATION shall be the personal liability of
 the permittee and/or the person engaged in mining  and  the  department,
 acting  by  the attorney general, may bring suit to recover all costs to
 secure the reclamation AND DAMAGES DIRECTLY OR INDIRECTLY RESULTING FROM
 SALT MINING ACTIVITIES BENEATH A LAKE not covered by the financial secu-
 rity.  The  materials,  machinery,  implements  and   tools   of   every
 description  which  may  be  found  at  the mine, or other assets of the
 permittee and/or the person engaged in mining shall be subject to a lien
 of the department for the amount expended for  reclamation  of  affected
 lands,  AND  FOR MAKING WHOLE ANY PARTIES SUFFERING ANY DAMAGES DIRECTLY
 OR INDIRECTLY RESULTING FROM SALT MINING ACTIVITIES BENEATH A LAKE,  and
 shall not be removed without the written consent of the department. Such
 lien  may  be foreclosed by the attorney general in the same manner as a
 mechanic's lien. Any and all moneys recovered shall be deposited in  the
 environmental  regulatory  account  pursuant  to section 72-1009 of this
 chapter.
   7. Political subdivisions, municipalities, the United States  and  any
 of  its  agencies  and  agencies  of  the state shall be exempt from the
 requirements of this section.
   8. ANY PERMITTEE WHICH HAS FURNISHED A FINANCIAL SECURITY WITH RESPECT
 TO SALT MINING BENEATH A LAKE  WHICH  IS  NOT  IN  COMPLIANCE  WITH  THE
 REQUIREMENTS  OF  THIS SECTION ON THE EFFECTIVE DATE OF THIS SUBDIVISION
 SHALL BE IN VIOLATION OF THIS SECTION IF SUCH FINANCIAL SECURITY IS  NOT
 BROUGHT INTO COMPLIANCE WITHIN SIX MONTHS OF SUCH EFFECTIVE DATE.
   §  3.    Section 81 of the public lands law is amended by adding a new
 subdivision 3 to read as follows:
   3. NOTWITHSTANDING SUBDIVISIONS ONE AND  TWO  OF  THIS  SECTION,  WITH
 RESPECT  TO  A  PERMIT,  CONSENT,  OR  LEASE ISSUED WITH RESPECT TO SALT
 MINING ACTIVITIES BENEATH A LAKE, THE DURATION OF SUCH PERMIT,  CONSENT,
 OR  LEASE  SHALL  NOT  BE  LONGER  THAN THE DURATION FOR WHICH MINING IS
 ALLOWABLE UNDER THE PERMIT ISSUED BY  THE  DEPARTMENT  OF  ENVIRONMENTAL
 CONSERVATION  PURSUANT  TO TITLE TWENTY-SEVEN OF ARTICLE TWENTY-THREE OF
 THE ENVIRONMENTAL CONSERVATION LAW IN RESPECT OF SUCH MINING.
   § 4. Severability. If any provision of this act, or any application of
 any provision of this act, is held to be invalid, that shall not  affect
 the  validity or effectiveness of any other provision of this act, or of
 any other application of any provision of this act, which can  be  given
 effect  without  that  provision  or  application;  and to that end, the
 provisions and applications of this act are severable.
 S. 2053--A                          5
 
   § 5. This act shall take effect on the thirtieth day  after  it  shall
 have become a law; provided, however, that section two of this act shall
 take  effect  on  the  ninetieth  day  after it shall have become a law.
 Effective immediately, the addition, amendment and/or repeal   of    any
 rule    or regulation necessary   for  the implementation of this act on
 its effective date are authorized to be made and completed on or  before
 such effective date.

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Senate Bill S2053

Sponsored By

Current Bill Status - In Senate Committee Environmental Conservation Committee

Bill Amendments

co-Sponsors

2025-S2053 - Details

2025-S2053 - Summary

2025-S2053 - Sponsor Memo

2025-S2053 - Bill Text download pdf

co-Sponsors

2025-S2053A (ACTIVE) - Details

2025-S2053A (ACTIVE) - Summary

2025-S2053A (ACTIVE) - Sponsor Memo

2025-S2053A (ACTIVE) - Bill Text download pdf

Comments

Senate Bill S2053

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Sponsored By

Lea Webb

Current Bill Status - In Senate Committee Environmental Conservation Committee

Bill Amendments

co-Sponsors

Rachel May

Pete Harckham

2025-S2053 - Details

2025-S2053 - Summary

2025-S2053 - Sponsor Memo

2025-S2053 - Bill Text download pdf

co-Sponsors

Rachel May

Pete Harckham

2025-S2053A (ACTIVE) - Details

2025-S2053A (ACTIVE) - Summary

2025-S2053A (ACTIVE) - Sponsor Memo

2025-S2053A (ACTIVE) - Bill Text download pdf

Comments