We are still reading, analyzing and "peeling back the onion", but here are FOL's initial comment's on the DEP Environmental Assessment Letter:

1. As evidenced by its very detailed response letter, DEP is doing a thorough job in analyzing, and questioning, every element that Keystone submitted as purported Benefits.

2. We agree with all ten items that the DEP has indicated it will NOT consider as a Benefit. In the Harms-Benefits Analysis that Friends of Lackawanna submitted earlier this year, we also stated that each of those ten items should be disqualified.

3. We believe that as DEP receives more details on the six purported benefits it categorized as "require additional information," they too should be removed from the analysis.

4. As DEP keeps thoroughly peeling back this onion, the more "benefits" will be eliminated from consideration. What will be left is mostly items that revolve around money.

5. Ultimately, because many of the non-monetary benefits are correctly being disqualified, this analysis may come down to one simple variable: cash. Specifically, is the money that this Landfill has to pay either by statute (State fees or payments to host cities) or as a cost of doing business (payroll, goods and services), enough? Are those fees enough to let this Landfill dominate our region for the next five decades?

6. At some point, every benefit that KSL is given credit for will run out. However, the harms and potential harms can go on forever. Once the variable of time is taken into consideration, the benefits simply cannot outweigh the harms. And it isn't even close.