Justice For Our Climate
A few weeks ago, Janos Marton suspended his campaign for Manhattan DA, largely over concerns that New York’s political process overstated the role of fundraising from large donors.
You can read his full statement here:
After some reflection, our campaign decided to release this final policy document, which had been close to completion at the time, with the hope that other candidates, one of whom will be the next Manhattan DA, will adopt and implement these ideas.
I am running for Manhattan District Attorney to transform New York’s criminal justice system and hold special interests accountable. We have turned a blind eye to harmful impacts of corporate environmental crime for too long, especially as we confront the crisis of climate change. As Manhattan DA, I will fight for our climate as part of our duty to keep New Yorkers safe.
Environmental crimes include harms to our climate, and there is a renewed urgency to hold violators of those laws accountable given that the island of Manhattan has become increasingly vulnerable to coastal storms and flooding.¹ Environmental crimes also include threats to our health, such as the air pollution that disproportionately increases asthma rates and the spread of infectious diseases in low-income neighborhoods.²³ The job of the Manhattan District Attorney is to keep New Yorkers safe, and for too long we have ignored the negative health and environmental impacts of our current policies on marginalized communities. Especially after COVID, this attitude must change.
Finally, on a personal level, I was moved to run for Manhattan DA in part because of a piece, Losing Earth: The Decade We Almost Stopped Climate Change, by Nathaniel Rich. Learning about the failures of the early climate change movement to enact transformative change drew parallels to our current criminal justice movement, which for all of its energy, money, and publicity has failed to significantly reduce America’s enormous jail and prison population. Given the vast discretionary power of the District Attorney’s offices, and the role of the Manhattan DA’s office as a national leader, there is no better way to accelerate the desperately needed reforms to the criminal legal system than electing DAs who believe in dismantling mass incarceration.
New York City’s Worst Environmental Offenders:
Because the public is rarely educated on the nature of environmental crime, it is worth highlighting the misconduct of the two worst local offenders: Con Edison and National Grid, which provide electricity, gas, and steam to millions of New Yorkers. Con Ed has accrued more than 300 pollution violations from New York State in the past few decades.⁴ National Grid received 1,616 safety violations involving a single project in Queens in 2019 alone.⁵
Both ConEd and National Grid have profitably operated while committing numerous safety violations and preventable explosions and blackouts due to neglect, while rarely receiving more than a slap on the wrist or a menial fine.⁶ ConEd’s yearly revenue is approximately $12 billion while National Grid’s US revenue was $2.3 billion.⁷⁸ A program created in 2009 with an allocated budget of $350 million that was supposed to modernize relay protection systems was continuously delayed and ultimately terminated would have most likely prevented the West Side blackout during the summer heat on July 12, 2019.⁹¹⁰ Thousands of residents in the other four boroughs were left without electricity over the next few days, and preemptively cut power to nearly 50,000 residents in predominantly Black neighborhoods in Brooklyn less than two weeks later.¹¹¹²¹³¹⁴¹⁵¹⁶¹⁷
Slap on the wrist fines to these corporate behemoths do not appear to deter bad behavior. A ConEd oil spill in 2017 that released tens of thousands of gallons of oil into the East River resulted in a fine of merely $636,000.¹⁸ Less than 8,000 of the approximately 30,000 gallon were collected as part of ConEd’s requirement to clean the remnants.¹⁹²⁰ The Department of Environmental Conservation has refused to publicly release decades worth of ConEd oil spills, leaving the public in the dark as to the extent of the harm they cause.²¹
My office will zealously investigate environmental crimes and treat them like any other offense. We will hold executives at the top directing these actions individually accountable and enact steeper fines that create a significant economic impact on businesses. By doing so, we can make the chance of being prosecuted for committing these crimes too high for companies to risk the consequences and no longer a part of their business model. If these worst violators are continuously let off the hook, we send the message to others that this office does not take environmental law seriously.
Our Solutions for Addressing Climate Change and Environmental Crimes in New York City:
After consulting with climate change advocates, environmental and animals rights activists, community leaders, and legal experts, we propose the following:
Proposal #1: Build a Strong Environmental and Climate Crimes Unit at the Manhattan DA’s Office
When I was special counsel to the Moreland Commission, we chose notorious industries to focus our corruption investigations, and I’ve previously advocated for such an approach in our campaign policy plan for combatting wage theft. As Manhattan District Attorney, I will do the same with power supply companies, industries who engage in illegal dumping, buildings that violate lead abatement laws, and scofflaw gas and electric utility suppliers.
Too often we focus on individual responsibility when speaking about the environment. It is my office’s goal to bring the focus back to large corporations who are the greatest polluters by holding them accountable for environmental transgressions.
Upon the recommendations of environmental activists, my office will build a strong Environmental and Climate Crimes Unit, staffed with experienced environmental regulators that will investigate safety violations, dumping illegal and toxic waste, labor abuse, and the lack of enforcement of lead paint abatement. I will increase penalties for dumping illegal and/or toxic waste to actually deter these acts and prosecute individuals from any corporation found to be directing or complicit in such behaviors. These investigations will focus on preventable explosions, knowingly ignoring faulty infrastructure, and excavation violations.
By establishing teams to investigate Manhattan’s worst environmental offenders, which will also focus on egregious acts of safety, labor, and billing violations, our office will finally put an end to the harmful tactics that have become just another part of doing business. Robust investigations will begin immediately into industries and corporations with the most rampant history of these types of transgressions.
We believe that the Manhattan District Attorney must take a far more visionary role when it comes to environmental and climate crimes, and establish the office as an ally in the critical effort to protect our city and our planet.
In addition to the dedicated attorneys who will work solely on environmental crimes, we pledge to add investigators and community liaisons to proactively combat these hazards. Our community liaisons will build relationships with community groups, unions, activists, and advocacy groups to gain additional insight into bad actors and continuous offenders.
My office will be transparent to the public about all investigations and subsequent prosecutions. Our new unit will release an annual report on environmental cases each year, which is not the current practice of the office, and in doing so, bring accountability to our new unit’s work. This will also signal to would-be lawbreakers that environmental law is taken seriously in our office, which would deter illegal conduct.
Labor abuse will be investigated in conjunction with our Wage Theft Unit, including knowingly using unsafe and noncompliant actions during construction, not providing workers proper PPE both before and especially during COVID-19, refusing to pay outside contractors a prevailing wage, and forbidding the formation of unions.²²²³²⁴²⁵²⁶²⁷²⁸ We must protect workers at all times, especially those on the frontlines during a global pandemic.
Other activities our Environmental Crimes Unit will look into will include predatory marketing tactics used by energy service companies (ESCOs),²⁹ billing issues (such as raising rates in May during the height of COVID),³⁰³¹³² bribery, tax fraud, and other corruption by high ranking executives in these industries.³³³⁴
Proposal #2: Break the Cycle of Harm by Enforcing Industry Standards
Despite New York State having a strong history of passing environmental legislation and protecting its wildlife, in recent decades there has been a decline in environmental prosecutions for offenders.³⁵ We firmly believe that jail and prison should never be the answer to society’s problems but that does not mean people should not be held accountable for the harmful acts they commit.
Over the last 15 years, law enforcement agencies at the state and federal level have been incredibly reluctant to truly hold corporations accountable for fraud and other crimes. There are a host of reasons for this — politics, the complexity of proving certain types of financial crime, limited resources — but we can clearly do better.
First, I will increase the resources for our Major Economic Crimes Bureau, which will be made possible by reducing the number of attorneys working on low-level criminal offenses. Second, I will seek more consequential outcomes for corporate institutions that break the law, including prosecution of leadership in those companies and loss of equity; for example, fining a company by giving a share of their stock equity to victims. This is much better than regular fines, which companies consider the cost of doing business. Third, I will create a greater monetary incentive for whistleblowers, which certain federal agencies use to great success.
Fourth, I will make sure deferred prosecution agreements (DPAs) are not just a get out of jail free card for corporations. Right now, if a company gets in trouble, law enforcement lacks the resources to do a proper investigation, so they agree to a DPA — allowing for an internal investigation (by a corporate law firm) in lieu of prosecution. These investigations usually lead to recommendations on improving corporate governance, and occasionally consequences for low-mid level employees. Too often this is a sham resolution, and one solution is to develop a set list of law firms (such as plaintiff firms) that can do more rigorous corporate investigations in partnership with our office. Taken together, these reforms will keep the pressure on environmental institutions.
Large corporations such as ConEd and National Grid must be held to the highest standards and receive appropriate consequences. We will hold all types of businesses accountable, but recognize that District Attorney’s offices taking on corporate crime are often tempted to take on easier cases against small businesses than go up against powerful forces. We can only challenge corporate power and win by working in collaboration with others.
That’s why our office will work to build partnerships with community organizations, activists, advocacy groups, and those most directly impacted from climate injustice, including Indigenous people. Building this trust will help to remedy harm, and promote peacebuilding and restorative justice practices as successful outcomes of justice. We hope this will also work to repair harm at the community level, which is the central message of our campaign.
When we encounter offenders engaging in smaller environmental crimes such as a restaurant violating styrofoam laws, a restorative approach would be better than criminalization. The purpose of restorative justice (“RJ”) is to hold the person who has committed harm accountable, heal the person who has been harmed, and use the community’s support to ensure that the harm does not re-occur. Our campaign has previously released a comprehensive restorative justice plan that will extend to environmental crimes.
The goal here, as with all RJ processes, would be to address the underlying cause of harm, so that person would not continue the harmful behavior in the future. These procedures could also be combined with required courses about the climate crisis and why these behaviors have such a detrimental effect on advancing climate change. RJ processes would only be disfavored in cases of systemic corporate crime, where accountability is hard to trace to all of the relevant parties.
Proposal #3: Establish an Animal Cruelty Prosecutions Unit
Protecting animal rights is integral to addressing climate change, which is perhaps the most essential justice issue all humans face. The way we treat animals reveals our society’s moral compass. In order to pursue a true vision, this vision must include all living beings, including animals. I will establish an Animal Cruelty Prosecutions Unit within our broader Environmental and Climate Change Crimes Unit, where staff could work with other colleagues looking at expansive interpretations of environmental laws and other statutes outside of the typical day to day issues most of our attorneys will be working with. I will hire people with experience working on behalf of animals to staff this unit, in conjunction with experienced litigators who share the values needed to staff such a unit.
This unit will investigate all forms of animal cruelty and the industrial meaptacking industry which still exists today in Manhattan, including protecting wildlife, investigating any illegal poultry operators, and following leads on illegal dogfighting and other animal fighting rings. Given the recent news that Mayor de Blasio’s Office of Animal Welfare is barely operational, with a single employee, we will also look into cases of animal neglect and other domestic abuse.³⁶ In addition, a task force will be created to investigate the antiquated horse-drawn carriage industry in its entirety.
I also pledge to release an annual Animal Abuse registry, as proposed by Assemblymember Linda Rosenthal.³⁷ This list will include every individual brought before our office who has abused, neglected, or otherwise harmed an animal so animal rescue organizations will be able to protect animals when placing them for adoption.
Proposal #4: Ensure the Manhattan DA Is a Green Office
Climate change will also be a priority within my own office. I will ban plastic water bottles, plastic straws and other single use items, reduce food waste, and encourage employees to use public transit or bicycles when commuting to the District Attorney’s office. I also pledge to use public transit whenever possible while I am in office.
The District Attorney’s office, and the greater New York court system, are incredibly outdated. I will prioritize digitizing the office as quickly as possible upon taking office. In the year 2021, there is no reason that criminal court still looks unchanged from the 1980s, with ADA’s walking around with huge volumes of paper files. This step will be part of a broader plan to modernize the District Attorney’s office and will hopefully move the greater Manhattan court system towards doing the same.
Proposal #5: Support Legislation That Protects Against the Impacts of Climate Change
The Manhattan DA’s office is part of a broader political system. We will always use the bully pulpit in our office to advance legislative, executive, and administrative policies in line with our vision of a more just society, including legislation that will protect our city from the impacts of climate change and reverse a century of environmental racism. We support the following legislation and programs, some of which have been discussed previously in this paper.
- Renewable Rikers: As the former manager of the #CLOSErikers campaign, I am incredibly inspired by the Renewable Rikers Act, the effort to replace the jail complex with a renewable energy system to deliver power for the city. Rikers Island has been a moral stain on our city, and transforming the island from a jail complex run by DOC to green infrastructure is a smart and just investment.³⁸
- Lead Poisoning Enforcement: Despite the overwhelming evidence of the harm caused by lead paint, and its abundance in NYCHA buildings, there is no statewide system of preventions. We support the bill Senator Brian Kavanagh is set to introduce in January 2021 which is expected to develop a system of standards for enforcing inspections of lead in homes along with a publicly available database on such violations.³⁹
- Public Power NYC: I believe our energy should be supplied by the public sector, and support DSA’s Public Power campaign. The goal must be to transition to a publicly owned utility and replace corporations such as ConEd and National Grid who are consistently committing violations of environmental crimes.⁴⁰
- Protecting Animals’ Rights: Assemblymember Linda Rosenthal has introduced several important bills under her 2019 “Paw-Print”, all of which this campaign supports.⁴¹ As District Attorney, I pledge to support legislation that helps clarify the rights of nonhuman animals, and I will make the same commitment here that I’ve consistently made in this campaign — to listen closely to communities most directly impacted and most expert in the particular issue, including activists who are pioneering on this issue.
- Prevent Diesel Truck Emissions: New York State has lagged behind its counterparts in putting a stop to diesel truck emissions. As proposed by advocate Charles Komanoff, Attorney General Letitia James could take a proactive approach to this problem by following the example of California and shutting down the supply chain of those who manufacture, distribute, and sell emission tampering devices.⁴²
- More DA Enforcement of State Level Legislation: Currently, too much environmental regulatory power is vested in the governor’s office. For example most provisions of the New York State Green New Deal are enforced by the New York State Department of Environmental Conservation, which is essentially relying on Governor Cuomo to determine what accountability will look like. (This year, Cuomo also declined to pass a foam ban bill passed unanimously by the legislature.)⁴³⁴⁴ More local level enforcement from the state’s 62 District Attorneys will create greater accountability, and thus a healthier environment, for all New Yorkers.
This campaign is born from the belief that the District Attorney’s office should represent the same bold, progressive values and vision we insist on in other elected officials in this city. It is a campaign that stands on the shoulders of all who have fought, and continue to fight, to build New York’s progressive tradition. Climate change is an issue that impacts every single person in New York City, yet has been frequently been ignored by our District Attorneys.
In ending cycles of harm, the best long-term solutions will be found in investments we make outside of the criminal justice system — investments in our environment, infrastructure, education, housing, and economic opportunity. On this issue, it is especially clear that other people in government must act swiftly and decisively to avert a growing crisis — but New Yorkers should know they have an ally in the Manhattan DA’s office.
As with all of our policy proposals, we welcome and incorporate feedback, especially from those who have been impacted by the system or worked within it, and we will maintain this as a living document, through Election Day and our taking power at the District Attorney’s office. Together, we can build a safer and more just New York.
The Marton for District Attorney campaign believes in the principle that those closest to the problem are closest to the solution, and we will work with community partners to generate our policy agenda. If you feel something can be improved in this proposal, contact JanosForDA@gmail.com with the subject line, “Climate Change”.
You can read about all of the issues our campaign has led on at JanosForDA.com/issues, including:
Proposal to transform how mental health is handled within our criminal legal system by using virtually all financial forfeitures to fund community-based mental health programs. (November 24, 2020)
Proposal to combat wage theft, by protecting workers and holding corporations accountable. (September 8, 2020).
Proposal to implement restorative justice in Manhattan, and create accountability and healing without using jail or prison. (July 22, 2020).
Proposal to reimagine our response to intimate partner violence as part of a much broader approach to repairing the Sex Crimes Unit. (July 7, 2020).
Proposal to generate police accountability by achieving greater independence from the NYPD, holding the NYPD broadly and individually accountable for misconduct, and reducing the role of policing and prosecution. (June 26, 2020).
Proposal to eliminate solitary confinement for Manhattan defendants. (March 11, 2020).
Proposal to end the War on Drugs and refocus drug policy enforcement using a public health lens. (January 16, 2020).
Proposal to bring humanity to prison sentencing by shortening prison sentences, fixing our oppressive plea bargain system, and parole reform. (December 13, 2019).
Proposal to commit to 80% Decarceration through our many reforms to pretrial detention. (October 20, 2019).
 New York City Office of Emergency Management, Hazard Mitigation: NYC Risk Landscape — Coastal Storms, https://www1.nyc.gov/assets/em/downloads/pdf/hazard_mitigation/nycs_risk_landscape_chapter_4.1_coastalstorms.pdf (accessed November 23, 2020)
 Sonia Altizer, Richard S. Ostfeld, Pieter TJ Johnson, Susan Kutz, and C. Drew Harvell. “Climate Change and Infectious Diseases: From Evidence to a Predictive Framework.” Science 341, №. 6145 (2013): 514–519.
 Erin Durkin, “NYC’s Poorest Neighborhoods Have Highest Death Rates from Coronavirus”, Politico New York, May 18, 2020, https://www.politico.com/states/new-york/city-hall/story/2020/05/18/poorest-nyc-neighborhoods-have-highest-death-rates-from-coronavirus-1284519 (accessed November 27, 2020)
 Gabriel Sandoval, “State Refuses to Release Decades of Con Edison Pollution Reports, Lawsuit Charges”, The City, July 9, 2020, https://www.thecity.nyc/environment/2020/7/9/21319616/state-refuses-to-release-con-edison-pollution-reports (accessed December 3, 2020)
 Aaron Eisenberg, “Opinion: National Grid Has No Place in NYC’s Climate-Resilient Future”, City Limits, October 21, 2020, https://citylimits.org/2020/10/21/opinion-national-grid-has-no-place-in-nycs-climate-resilient-future/ (accessed December 7, 2020)
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 Staff, “Consolidated Edison Company Profile, Fortune 500, Rank 256”, Fortune, May 18, 2020, https://fortune.com/company/consolidated-edison/fortune500/ (accessed January 4, 2021)
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 James Barron and Mihir Zaveri, “Power Restored to Manhattan’s West Side After Major Blackout”, The New York Times, July 13, 2019, https://www.nytimes.com/2019/07/13/nyregion/nyc-power-outage.html (accessed December 2, 2020)
 Staff, “Another Power Outage Hits Staten Island, Thousands Of Con Ed Customers Affected For Second Straight Day”, CBS New York, July 17, 2019, https://newyork.cbslocal.com/2019/07/17/power-outage-staten-island-con-ed/ (accessed December 3, 2020)
 Jen Chung, “Neighborhoods Experience Power Outages Across NYC”, Gothamist, July 18, 2019, https://gothamist.com/news/neighborhoods-experience-power-outages-across-nyc (accessed December 3, 2020)
 Jake Offenhartz, “Con Ed Intentionally Cut Power to Swaths of Brooklyn Amid Heat Wave”, Gothamist, July 22, 2019, https://gothamist.com/news/con-ed-intentionally-cut-power-to-swaths-of-brooklyn-amid-heat-wave (accessed December 3, 2020)
 Chandler Kidd, “Power Outrage: PLG Lawmaker Accuses Con Edison of Leaving Communities of Color In the Dark”, Brooklyn Paper, July 24, 2019, https://www.brooklynpaper.com/power-outrage-plg-lawmaker-accuses-con-edison-of-leaving-communities-of-color-in-the-dark/ (accessed December 3, 2020)
 We approve of the New York State Public Service Commission’s investigation into these power outages and the recommended $25 million fine though we are still concerned without actual operating penalties being levied, these practices may still continue, especially considering over 180,000 customers were once again left without electricity during a single storm this summer.
 Office of Governor Andrew M. Cuomo, “Governor Cuomo Announces Con Edison Facing $25 Million in Penalties for Failures Related to 2019 Power Outages in Manhattan and Brooklyn”, November 19, 2020, https://www.governor.ny.gov/news/governor-cuomo-announces-con-edison-facing-25-million-penalties-failures-related-2019-power (accessed December 3, 2020)
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 The same transformer had leaked 179 times prior to the 2017 East River spill.
 Gwynne Hogan, “Con Ed Site of Recent East River Spill Leached Oil 179 Times Before: DEC”, DNA Info, May 18, 2017, https://www.dnainfo.com/new-york/20170518/dumbo/con-edison-oil-spill-east-river-riverkeeper-dec (accessed December 3, 2020)
 New York State Department of Environmental Conservation, “DEC Announces $636,015 in Penalty and Restoration Funding for 2017 Con Edison Discharging to East River from Farragut Substation”, September 26, 2018, https://www.dec.ny.gov/press/114761.html (accessed December 3, 2020)
 Gabriel Sandoval, “State Refuses to Release Decades of Con Edison Pollution Reports, Lawsuit Charges”, The City, July 9, 2020, https://www.thecity.nyc/environment/2020/7/9/21319616/state-refuses-to-release-con-edison-pollution-reports (accessed December 3, 2020)
 Staff, “NYC Excavation Workers Say ConEd Contractor Owes Wages”, Law360, October 30, 2020, https://www.law360.com/articles/1324490/nyc-excavation-workers-say-coned-contractor-owes-wages (accessed December 3, 2020)
 Eight ConEd employees have died of COVID and over 700 had contracted the virus as of June 2020. The Utility Workers Union of America Local 1–2 members who work at ConEd voted to authorize a strike this June, which was averted in the final hours with a deal agreement that would have otherwise caused over 8,000 workers to walk off the job.
 Iulia Gheorghiu, “Con Edison Reaches 170 Confirmed COVID-19 Cases, 3 Deaths, as Risks Rise for Utility Workers”, Utility Dive, April 3, 2020, https://www.utilitydive.com/news/con-edison-reaches-142-confirmed-covid-19-cases-2-deaths-as-risks-rise-fo/575417/ (accessed December 3, 2020)
 Robert Walton, “ConED COVID-19 Cases Grow Past 350 as Utilities Forced to Adjust Pre-Pandemic Emergency Plans”, Utility Dive, https://www.utilitydive.com/news/coned-covid-19-cases-grow-past-350-as-utilities-forced-to-adjust-pre-pandem/576606/ (accessed December 3, 2020)
 News 12 Staff, “Con-Ed, Utility Workers Avoid Strike with Tentative Deal Overnight”, News 12 Westchester, June 20, 2020, https://westchester.news12.com/coned-utility-workers-avoid-strike-with-tentative-deal-overnight-42271170 (accessed December 2, 2020)
 Reuters Staff, “Union Issues Strike Authorization for New York Con Edison Worker”, Reuters, June 11, 2020, https://www.reuters.com/article/consolidated-edi-union-strike/union-issues-strike-authorization-for-new-york-con-edison-workers-idUSL4N2DO341 (accessed December 2, 2020)
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 Claire Lampen, “Con Ed Asks Queens Man to Pay Nearly $38 Million on His Electric Bill”, Gothamist, March 12, 2019, https://gothamist.com/news/con-ed-asks-queens-man-to-pay-nearly-38-million-on-his-electric-bill (accessed December 3, 2020)
 Staff, “Hey New York, You Just Grossly Overpaid for Electricity This Past Summer”, Thrillist, November 4, 2016, https://www.thrillist.com/money/new-york/why-is-my-electric-bill-so-high-estimated-electricity-bills-explained (accessed December 3, 2020)
 Ashley Dawson, “Cracking ConEd’s Grip On Our Electric Supply and Replacing it With Public Power”, The Indypendent, August 26, 2020, https://indypendent.org/2020/08/cracking-coneds-grip-on-our-energy-supply-and-replacing-it-with-public-power/ (accessed December 3, 2020)
 Sarah Wallace, Rana Novini and Jonathan Dienst, “National Grid Workers, Brooklyn Landlords Among 37 Indicted in Alleged Gas Meter Scheme”, NBC News 4 New York, https://www.nbcnewyork.com/news/local/gas-meter-scheme-brooklyn-national-grid-landlord-bribe-arrest-indictment-crime-new-york-prosecute/99787/ (accessed December 3, 2020)
 James J. Periconi, “The State of Environmental Crimes Prosecutions in New York.” Natural Resources & Environment 23, №. 3 (2009): 11–15.
 Gabrielle Fonrogue, “Mayor’s Office of Animal Welfare Barely Functioning”, New York Post, December 2, 2020, https://nypost.com/2020/12/02/mayors-office-of-animal-welfare-barely-functioning/ (accessed December 3, 2020)
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 Charles Komanoff, “KOMANOFF: New York, U.S. Must Reverse the Charges on Diesel Tampering”, Streetsblog, December 7, 2020, https://nyc.streetsblog.org/2020/12/07/komanoff-new-york-u-s-must-reverse-the-charges-on-diesel-tampering/ (accessed December 7, 2020)
 Rick Karlin, “State Legislation Bans Toxic Foam Burning in Cohoes”, Albany Times-Union, June 10, 2020, https://www.timesunion.com/news/article/State-legislation-bans-toxic-foam-burning-in-15329887.php (accessed November 29, 2020)
 Lee Harris, “Cuomo Pushes to Weaken Ban on Toxic Foam Burning”, New York Focus, November 9, 2020, https://www.nysfocus.com/2020/11/09/cuomo-pushes-to-weaken-ban-on-toxic-form-burning/ (accessed November 29, 2020)