Kathy K
(address removed for public posting)
December 2, 2008

Scope Comments
Bureau of Oil & Gas Regulation
NYSDEC Division of Mineral Resources
625 Broadway, 3rd Floor
Albany, NY 12233-6500

Subject: Scope Comments

To Whom It May Concern:

In the DEC’s 1992 GEIS, Chapter XV – INTERAGENCY COORDINATION: BRINE DISPOSAL, UNDERGROUND INJECTION AND OIL SPILL RESPONSE, section C. COMPLAINT RESPONSE, subsection 1. Water Supply Problems. The DEC has stated that “(T)he initial response to water supply complaints is best handled by the appropriate local health office, which has expertise in dealing with water supply problems.” Included in the section regarding complaints about individual household water supply problems (page 15-5) it states “The lack of mandated approval for individual water supply system construction also complicates complaint investigations. The DOH and most county health departments will not sample well supply systems with substandard construction because poor construction can facilitate the movement of contaminants into water supplies, and water quality in these systems dramatically change in response to conditions such as recent precipitation.”

Due to the scale and method of extraction, the Final Scope must evaluate each county’s ability to provide initial response to water supply complaints related to natural gas extraction. The need for increased staff as well as education in the types of complaints generated from natural gas extraction must be addressed.

As an alternative, the DEC must evaluate whether or not the initial response to water supply problems, within a certain distance of a natural gas well drilling site (that distance to be determined by the DEC by study, with raw data, methodology and conclusions to be provided in the GEIS) should be handled at the state level, especially since the “DEC’s Oil, Gas and Solution Mining Law supersedes all local laws relating to the regulation of oil and gas development except for local government jurisdiction over local roads or the right to collect real property taxes.” (quoted from page 3 of the Draft Scoping Document, Well permit Issuance for Horizontal Drilling and High-Volume Hydraulic Fracturing to Develop Shale and Other Low-Permeability Gas Reservoirs).

Whether the initial response to water well complaints is determined to be the County Department of Health or the DEC, this agency will hereinafter be referred to as “the responsible agency”.

Items to be studied and addressed include:

• If there are water supply complaints within a certain distance (that distance to be determined by the DEC via study, with raw data, methodology and conclusions to be provided in the GEIS) from where gas drilling has commenced, will the responsible agency respond to the complaint regardless of the construction of the well supply system? If any water well complaint develops after gas drilling commences, will the responsible agency respond to the complaint regardless of the construction of the well supply system? Will the IOGA (Independent Oil and Gas Association) fund the responsible agency so that the responsible agency has the resources to conduct these inspections? What information will the IOGA provide to the responsible agency so that the agency will understand under which conditions a complaint may be oil and gas related?
• If the responsible agency has the resources to develop a formal procedure “under which (the responsible agency) will respond to and investigate initial complaints on oil and gas operations to determine if the complaint is oil and gas-related and to provide determinations of possible public health problems” (quoted from page 15-5 of the Final Generic Environmental Impact Statement on the Oil, Gas and Solution Mining Regulatory Program).
• The 1992 GEIS states “To better protect the integrity of individual water supplies, the DEC Upstate Groundwater Management Program recommends the enactment of a State Water Well Construction Code and legislation for the licensing of water well drillers.” Water well drillers, as of January 1, 2003, are required to have passed a certification exam. The majority of wells in New York State, however, have been drilled with no certified well driller on site and no State Water Well Construction Code in force. Will the responsible agency undertake to inspect all water wells within a certain distance (that distance to be determined by the DEC via study, with raw data, methodology and conclusions to be provided in the GEIS) around a gas drilling site, to determine if the water well construction is sufficient to protect the water well supply from any water contamination problems, either from spills, runoff, drilling or hydrofracturing?
• If the responsible agency will not inspect these water wells, what protections do private water well owners, who are not leased with a gas company, have to ensure that their well water will be protected, regardless of the construction of their well?

An unacceptable response to these questions would be such that the natural gas well casing is sufficient to protect all ground water supplies. The DEC raised these arguments in the 1992 GEIS. There is no change in gas well drilling or gas well casing requirements to repudiate the matter of water well construction. This issue is still outstanding and must be studied and addressed, especially for those water well owners prior to January 1, 2003 who were not required to have a certified well driller on site during construction.

The second item that must be studied and addressed is historical and, specifically, cultural landmarks. According to the 1992 GEIS, “Most environmental resources are protected through siting restrictions and permit conditions.”

Since completion of the 1992 GEIS, it has become increasingly apparent that there are areas of Native American cultural importance, especially at the headwaters of river basins. Cultural sites in the headwaters were constructed in relationship to natural features of the land. The historic preservation offices of the Native American cultures that were present in the area prior to colonization must be contacted and consulted so that sites of cultural significance will be properly identified, evaluated and protected. The new GEIS must study and include information on Native American cultural sites in New York State and how those sites will be protected from impact. Because of the scale and method of gas drilling, siting restrictions and permit conditions should be re-evaluated to take into consideration not only the cultural site itself, but also the natural feature(s) of the land that the cultural sites were constructed near, or in relationship to, in order to protect both.

Third, the Draft Scope, section 1.0 INTRODUCTION, subsection 1.1 Description of the Proposed Action, states: “There is also potential for development of the Utica Shale using horizontal drilling and high-volume hydraulic fracturing and the Department is aware that this could bring use of those techniques to areas such as Otsego and Schoharie Counties, which would also be new to natural gas development. Other shale and low-permeability formations in New York may be targeted for future application of horizontal drilling and hydraulic fracturing if Marcellus and Utica development using this method is successful and the requisite infrastructure is in place. The Department proposes to satisfy the State Environmental Quality Review Act (“SEQRA”) for most of these operations through the preparation of a Supplemental Generic Environmental Impact Statement (“SGEIS”), which will be read and applied in conjunction with the existing Generic Environmental Impact Statement (GEIS) on the Oil, Gas and Solution Mining Regulatory Program.”

The Groundwater Protection Council (GPC) report on the DEC website (http://www.dec.ny.gov/docs/materials_minerals_pdf/GWPCMarcellus.pdf) states:
“The potential for impacts to surface water and groundwater from development of the Marcellus shale are expected to be minimal because of the regulatory requirements from state oil and gas
agencies involved and the practices operators are implementing to ensure fluids are contained. In evaluating the risk of fluids migrating up to reach groundwater; the depositional environment of
the Marcellus Shale that produced a thick blanket of Devonian-aged shales above the Marcellus should also be considered as this thick sequence of overlying shales act as series of confining
layers to prevent the vertical migration of fracturing fluids toward groundwater systems.” (page 16, Hydraulic Fracturing Considerations for Natural Gas Wells of the Marcellus Shale
Authors: J. Daniel Arthur, P.E., ALL Consulting; Brian Bohm, P.G., ALL Consulting; Mark Layne, Ph.D., P.E., ALL Consulting)

However, only light mention is made of the Marcellus shale in the geologic section of the 1992 GEIS. Specifically, Marcellus shale is mentioned in the following paragraphs:

“The base of the Hamilton Group of Middle Devonian age is marked by the Marcellus Formation. The first of several massive black shale formations of Middle and Upper Devonian age, the Marcellus will produce natural gas where it is sufficiently fractured to create a network of cracks, allowing the gas to migrate to the wellbore. The Marcellus Formation is the most strongly radioactive of the Devonian shales and is a good marker bed on gamma ray logs.” (page 5-23)

And

“Five of the Devonian shales have been identified as potential gas producers and these are, in ascending order, the Marcellus Formation in the lower part of the Hamilton Group and the Genesee, Middlesex, Rhinestreet and Dunkirk Formations. Eight small Devonian shale gas fields exist in the State, although presently most are shut-in. Although none form large fields, the huge area underlain by gassy shales makes them a significant contributor to New York’s resource base.” (page 5-28)

The 1992 GEIS also states “Some rocks, like shales, have very high porosities, but their low permeabilities make them poor oil and gas producers. Rocks with very low permeabilities are known as tight formations.”

Furthermore, the only stratigraphic section that has been provided by the DEC (http://www.dec.ny.gov/energy/33893.html ) is from SW New York State.

• Regulations must be put in place to prohibit horizontal drilling and hydraulic fracturing of the uppermost layer of shales, as well as any formations above the uppermost layer of shales, which, according to the GPC report, would not be protected by a “thick blanket of Devonian-aged shale” to “prevent vertical migration of fracturing fluids toward groundwater systems”.

• Shale layers in New York State are not always located underground. Due to geologic faulting and folding, there is a disparity in the geology amid New York State, crossing a short distance. Because of the great disparity in geology within New York State, an updated, exhaustive study of all New York State geology must be done and included in the GEIS, along with study of the impacts of horizontal drilling and hydraulic fracturing on this type of geology. All raw data, methodology, and conclusions in support of the findings must be provided.

• Updated stratigraphic sections must be provided as evidence of the sequence of shales overlying the Marcellus and Utica, in multiple parts of the state.

Sincerely,

Kathy K

Addendum submitted 12/5/08:

Subject: Scope Comments – Addendum to my comments of December 2, 2008

To Whom It May Concern:

This letter is being written in addendum to my comments of December 2, 2008, submitted in writing to the DEC at the December 2, 2008 Public Scoping Meeting at SUNY/Oneonta, Hunt Union Ballroom, 108 Ravine Parkway, Oneonta, NY.

I would like to make it clear that I fully support, as the first option, the alternative suggested by the DEC in the dsGEIS which states:

“7.0 ALTERNATIVE ACTIONS

• Alternatives to be reviewed by the dSGEIS will include (1) the prohibition of development of Marcellus Shale and other low permeability reservoirs by horizontal drilling and high-volume hydraulic fracturing…”

In the event that this alternative is not adopted, I am proposing my comments, heretofore submitted on December 2, 2008, as well as this additional comment.

As a second option, I am calling for a new GEIS to be completed by the DEC with respect to The Oil, Gas and Solution Mining Regulatory Program. The new GEIS should include the impacts from gas pipelines and greenhouse gas emissions.

Third, and in addition to my prior comments, honey bees must be studied. Honey bees roam up to 2 miles for nectar and water. They will take water from a variety of sources, including shallow water sources and/or water sources where they can stand at the edge of a water body and take water without drowning.

Because high-volume, high-pressure hydraulic fracturing requires chemical additives to complete the process, the DEC must study the effect(s) of honey bees ingesting these chemical additives, both in the diluted form that may be present in pits on site, and in concentrated form that may be present on site as a result of accidental spill or seepage of these chemicals, especially if they are combined with water or rain water. The effects of ingesting gas well brine, which will also be accessible to honey bees, must be studied.

Sincerely,

Kathy K

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Anne Marie Garti
[address removed for public posting]
December 2, 2008
Scope Comments
Bureau of Oil & Gas Regulation
NYSDEC Division of Mineral Resources
625 Broadway, Third Floor
Albany, NY 12233-6500
To whom it concerns:
Please consider these comments on the draft scope of work for a supplement to the generic
environmental impact statement on the oil, gas, and solution mining regulatory program.
The proposed supplement to the 1988 and 1992 draft and final GEIS is to address impacts
of horizontal drilling and high-volume hydraulic fracturing in the Marcellus Shale and
other low permeability gas reservoirs.
Section §617.8 of the State Environmental Quality Review Act (SEQRA) outlines the steps
required for the scoping process. The DEC, which is acting as the lead agency, has not
complied with the rules that it itself is supposed to enforce. Specifically, the requirements
found in sections §617.8 (b), §617.8 (f) (3), and §617.8 (f) (4), have not been followed.
“The extent and quality of information, … existing information, and required new
information, including the required methodology(ies) for obtaining new information; … an
initial identification of mitigation measures” are all missing from the document.
I request that a new draft scope of work be prepared and distributed, and any person or
entity that wishes to alter their testimony, or submit new testimony, be allowed to do so.
Also, after reading the 1988 and 1992 draft and final GEIS, I find the current draft scope of
work to be filled with many unwarranted and unsubstantiated assumptions.
Assumption # 1
The most pervasive assumption is that a supplement to a twenty-year-old draft and final
GEIS will be sufficient to protect the environment of half of the State of New York from
an entirely new form of gas drilling.
Fact # 1
A new GEIS is needed to study the full impacts of the new drilling techniques.
Twenty years ago the DEC studied the potential impacts of drilling vertical wells into
various sedimentary rock formations. The geographic area, well density, and impacts of
extraction were entirely different than what is being proposed today.

For example, the word “horizontal” does not appear once in any of the chapters of the
multi-volume draft and final GEIS. The word “fracing” is used twice, and the words
“hydrologic fracturing” appear six times. In all eight cases, the word “fracturing” is in
reference to vertical, not horizontal wells.
In the old GEIS, the anticipated fracking pressure for vertical wells was 2,000 to 3,500 psi.
The pressure used for horizontal wells in low permeable shale is 8,000 psi,. One might call
it high-volume, high pressure, hydraulic fracturing.
The new form of hydro-fracking is dependent on a toxic brew of chemicals whose impacts
were never reviewed in the old GEIS. While the proportion of these chemicals is small,
their volumes are significant because of the huge amount of water used. In addition, some
of these chemicals are extremely toxic in miniscule quantities.
In section 2.0 the DEC states, “Review will be focused on topics not addressed by the
original GEIS, with emphasis on potential impacts associated with the large volumes of
water required to hydraulically fracture horizontal shale wells using the slick water
fracturing technique. *** However, it is not the Department’s intent or objective to reopen
the 1992 Findings for any activity that was reviewed in the GEIS and which will
remain consistent.”
The point is that nothing remains consistent because the technique, scale, intensity,
location, and scope of the proposed activity are entirely different.
Assumption # 2
In section 2.1.2 the DEC states, “The Department has no record of any documented
instance of groundwater contamination caused by hydraulic fracturing for gas well
development in New York, despite the use of this technology in thousands of wells across
the state during the past 50 or more years. Division of Mineral Resources staff responsible
for permitting and oversight of gas well drilling since 1980 also do not recall any such
instance.”
By making this claim, the DEC is assuming that staff recall and department documentation
of groundwater contamination are complete and fulfill the requirements of SEQRA.
Fact # 2
No study has been performed to find out whether or not ground water contamination has
occurred. In addition, as stated in Assumption #1, NYS has no experience with horizontal
drilling and high-volume hydraulic fracturing, so the claim of having used “this
technology” for over 50 years is erroneous and misleading.
Groundwater contamination may have taken place before the DEC was formed, without
DEC notification, or with no DEC documentation of the events. For example, when
groundwater contamination occurred, the industry may have brought in water to affected
households, filtered dirty water, dug new water wells, paid landowners, or “solved” theproblem of contamination in some other manner. Or landowners whose wells were
contaminated may have lacked the resources to do anything about it.
The DEC should contact all current and past landowners whose land has been drilled to
find out whether or not there have been instances of contamination in vertical wells. In
addition, scientific literature, court documents and newspaper articles should be reviewed.
To learn about ground water contamination, the DEC needs to review the records of other
states where horizontal drilling and high-volume hydraulic fracturing has been taking
place.
Assumption # 3
The DEC assumes that because well casings (may) have protected ground water supplies in
vertical wells they will also do so in horizontal wells that will be fracked, and re-fracked, at
much higher pressures with greater amounts of water, sand, and other chemicals.
Fact # 3
Concrete breaks down, particularly under stress, as anyone can observe in foundations and
sidewalks.
When drilling vertically, or when fracturing rock in a vertical well, it may be possible to
contain the flow of materials up and down the drill hole if the casing has been perfectly
constructed. However, there are substantive questions about how long a well casing can
maintain its integrity, and whether the quantity of water being used in horizontal hydrofracking,
and the pressure under which it is being injected, will break down the cement.
The DEC needs to study the impact of higher pressures, increased volumes, and repeated
hydrofracking on well casings. The department also needs to study plugged wells to
determine how the concrete is decaying over time, and whether that decay threatens our
water and soil from subsurface contaminants. What happens if a plugged vertical well is
reopened and horizontal wells drilled through it? The DEC should also document how
many wells were never plugged, and discuss what will happen if a new well is fracked near
an older unplugged well.
Assumption # 4
The DEC assumes that toxic materials cannot migrate from horizontal drill holes through
layers of shale into water supplies, soil, or air.
Fact # 4
Geologists acknowledge that the layers of shale are filled with vertical cracks and fissures.
In some places these layers have been displaced so that the angle of sedimentation is no
longer horizontal, but folded and angled 45 degrees or more towards the surface.
The sediments that lie beneath our feet are not solid bedrock; they are porous and

permeable. They have been subjected to different forces, including tectonic pressures and
seismic activity that have created cracks and fissures. These openings allow liquids and
gases to move within the earth.
Even the DEC has admitted this:
“Once gas escapes from the wellbore, under certain geologic conditions it can travel
considerable distance either laterally or vertically and through natural fractures reach the
surface or infiltrate a water zone. Gas in an aquifer can enter the water wells which tap it.
The presence of gas in a water well presents a safety hazard. The gas can accidentally be
ignited at the water tap or it can build-up inside the house in explosive quantities.” [1988
DGEIS, chapter 10, p. 4-5]
Horizontal drill holes, unlike vertical wells, will not be cased. As the gas companies bore
through fractured sedimentary rock, they will create new pathways for the migration of
naturally occurring and injected toxic chemicals. Since nobody has a map of where these
cracks and fissures are located, their width, or their course, there is no way to know how
the liquids and gases will travel through the cracks, and when or where they might emerge
at the earth’s surface. Nor does anybody know how these cracks might change over time
with the use of high-pressure fracking, deep impact bombing, geothermal wells, or future
seismic or tectonic activity.
The new GEIS should include maps showing areas of potential seismic activity, fractures,
and how the number and intensity of fractures increase as you move east. It should also
include lists of the natural and injected materials that are chemically capable of seeping
through cracks into aquifers, or to the earth’s surface. The potential environmental impacts
of all these materials, including methane, (future) sequestered CO2, injected fracking
fluids, and radioactive gases should be reviewed.
Assumption # 5
In section 4.1 Noise, Visual and Air Quality Impacts, the DEC refers to the old GEIS,
where they are described “in terms of both the short duration well drilling phase – when
the well site is, in effect, a small construction site – and the long-term production phase
when such impacts are drastically reduced because the equipment used during drilling
operations is removed and the areas not needed for production operations are reclaimed.”
Fact # 5
The construction phase of drilling and fracking deep horizontal wells is likely to be long
term and continuous, so these old construction and production phases no longer apply.
A number of things make the assumptions in the GEIS totally out of date:
- The new spacing rule allows 16 well pads per square mile, which is denser than
before.
- The amount of materials needed to frack each well has increased exponentially.
- The amount of pressure needed to frack low permeable shale is 3 to 4 times what
was needed for vertical wells.
- The amount of time needed to drill and frack each well has quadrupled (from 1 or 2
weeks to 4, 5, or 6 weeks).
- Horizontal wells in shale have low pressure, and frequently need to be re-fracked.
- Horizontal wells often need compressors during the production phase, and these
noisy machines run 24/7.
It is likely that a property owner would be suffering the impacts of well drilling in one
spacing unit for over a year. If their property adjoins two or more units, then the
“construction phase” could be a multi-year process. By the time the first series of wells
have been drilled, they might need to be re-fracked.
When the well goes from “construction” to “production,” the noise emanating from the pad
does not diminish; it just switches from rigs to compressors.
Unlike construction zones, the noise, lights, visual blight, and air pollution would be
spewing forth 24 hours a day, 7 days a week.
Since the environmental impacts from horizontal drilling and high-volume hydraulic
fracturing are repeated and long lasting, they require a totally new environmental review.
The DEC should study noise levels and review literature on noise impacts of horizontal
drilling and high-volume hydraulic fracturing in other states. Monitoring equipment
should be established at set distances, and based on the information acquired, statewide
standards should be established. When houses or adjoining property lines fall within zones
of unacceptable levels, noise buffers around drilling sites should be required.
The DEC should study visual impacts by reviewing literature and making site visits to
other states where horizontal drilling and high-volume hydraulic fracturing have been
established. Statistics on spacing density and re-fracking activity in those states should be
published. Using that information, images of rigs and well pads should be superimposed
on aerial photographs of NYS. If done with a GIS system, topographical information and
spacing units can be layered onto the images, and impacts on a viewshed deduced.
The proposed drilling for natural gas in areas of low-permeable shale could affect many
areas of NYS where there are a substantial number of second home owners and/or in areas
where people have chosen their property, and made substantial investments to it, based on
existing patterns of open space. Information on population density and the average
number of acres per property owner per town should be gathered and published.
In addition, the new type of drilling will require larger well pads and this will affect hilly
and mountainous regions that were not studied in the last GEIS. The impact of changing
the topography of rural areas to create five or more acres of level land per well pad, at a
density of 16 pads per square mile, needs to be studied.
The proposed drilling could severely impact the pristine air quality in the southern half of
NYS. Exhaust from the huge number of diesel trucks, dust from construction activity,
emissions from wells that will be flared (either intentionally or accidentally), as well as the
evaporation of hazardous materials in waste pits, could lead to a profound deterioration of
NYS’ air quality. The use and emission of volatile organic compounds (VOCs) in fracking
fluids could have a profound impact on all ecosystems.
The DEC should study air quality levels and review literature on air quality impacts of
horizontal drilling and high-volume hydraulic fracturing in other states. Monitoring
equipment should be established at set distances in those states, and based on the
information acquired, standards established for NY. Strict regulations, such as the required
use of low sulfur fuel and the prohibition of toxic chemicals in hydro-fracking, should be
promulgated.
Assumption # 6
The old GEIS assumes that a municipal water supply can be impacted by a natural gas well
located 2000 feet away. Simultaneously it is assumed that a natural gas well can be
located 150 feet from a water well serving a single-family home with no impact at all.
Fact # 6
The discrepancy in standards and impact areas defies logic. If a municipal well can be
impacted at 2000 feet, then it is possible, depending upon the aquifer being tapped, that a
homeowner’s well can also be impacted at 2000 feet.
In the draft scope of work, it is implied that the NYC watershed area is somehow “more
sensitive” than other areas of the state. This is an unjustified prejudice, not a scientific
fact.
According to the old GEIS, over two million people are dependent on springs and wells for
their drinking water. Few of these families are financially able to either prove that a gas
driller has ruined their water supply or pay for a new source of water.
Updated information on the number of households dependent of springs and wells, as well
as the average income per household per town and county, should be gathered and
published. The costs of supplying water to a household, business, and farm if their well is
contaminated should also be provided.
The DEC should study surface and ground water contamination caused by horizontal
drilling and high-volume, high pressure hydraulic fracturing in other states. Based on that
information, strict, uniform, statewide regulations should be promulgated. There should be
equal protection for the water supplies of all New Yorkers.
Assumption # 7
In section 4.8 Community Character, the DEC refers back to section 4.1: “As with the
noise and visual impacts discussed above, any potential negative community impact
occurs primarily during the drilling phase, which includes stimulation and completion. The
impacts are similar to those of a construction site, analogous to road improvement or sewer
excavation projects, with similar potential for temporary community impacts.”
Fact # 7
The construction phase of drilling and fracking deep horizontal wells is likely to be long
term and continuous, so the DEC’s assumptions, based on its experience with vertical
wells, no longer apply. (For details see Fact # 5.)
A full build out of natural gas wells in the southern half of NYS will alter each rural
community beyond recognition.
The DEC should study social impacts and review literature on social impacts of horizontal
drilling and high-volume hydraulic fracturing in towns in other states. Information on
population changes, demands for services, fire and emergency budget rates, drug and
alcohol addiction rates, crime rates, etc. should be gathered and published.
Other Topics
The following topics have not been mentioned in the draft scope of work and need to be
studied:
1. Odors
It appears that there can be extremely unpleasant smells in gas drilling areas.
Information on what chemicals or minerals are causing these odors should be
provided, and methods of containment/mitigation should be developed
2. Lights
Well pads use high intensity lights while they are being developed. Standards
should be established so that all lights have hoods or protectors so that the light
only shines directly down, not laterally into other people’s property, or up into the
night sky.
3. Use of gray water
It has been suggested that one way to avoid water withdrawals is to use water from
wastewater treatment plants, or other industrial facilities, for fracking wells. This
could potentially lead to new contamination problems at the well pads, in drinking
water aquifers, or surface water supplies.
4. Wastewater treatment plants
It appears that local authorities may be asked to treat fracking fluids in municipal
wastewater treatment plants. The impacts of brine, arsenic, NORMS, and fracking
fluids on their equipment, operations, and discharge permits should be evaluated.
5. Illegal dumping
Study impacts from the illegal dumping of drilling waste and fracking fluids.
6. Health impacts
A full build out of the natural gas industry over half of NYS could have dire
consequences on people’s health, through soil, air, and water contamination. A full
study, preferable by the Department of Health, should be undertaken.
Thank you for consideration of my comments.
Anne Marie Garti

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