I am opposed to National Grid’s proposed fracked gas pipeline in the Capital District dubbed as “E37 Reliability and Resiliency Project”. First of all, National Grid (NG) did not consider alternatives to using a pipeline to transport their gas. In addition, they have also not demonstrated a sufficient need for gas.

Non pipeline alternatives were not seriously considered. Also, conservation was not seriously considered by NG either.

Renewable Energy and Energy Efficiency vs Nat Gas

Furthermore and in Westchester County, NY, state agencies have allocated over 250 million dollars to foster non pipeline alternatives. That’s instead of supporting Con Edison’s gas pipeline plans. This resulted in a Clean Energy Plan. For it’s NY Power Authority’s low cost financing. Moreover and ultimately Con Edison’s renewable incentives. These feasible alternatives should also be carefully looked at. As well as they should be adopted. Moreover by the lead agency, the Public Service Commission (PSC). It’s located in Albany and Rensselaer Counties.

Why not use the rate hike money ($70,000,000) to incentivize the use of geothermal heat. All for new growth and credit entities. Or why not use gas on the few peak demand days each year? With enough incentives, other alternatives will develop.

Furthermore, approval of the pipeline must be based on an application that relies on a need for supply. All due to certain average temperature days.

However, without supplying that factual basis in adequate specificity to support a project of this magnitude makes no sense. For it would be arbitrary and capricious. Even if that data were supplied. Yet it would have to be sufficient to support such a need.

Possible extreme cold days on the order of a few days a year would not constitute such a need. Nor would temperatures based on past data. I mean without valid projections of what future temperatures would then constitute such a need.

Also, NG admits there never has been shut off. Nor  they don’t forecast one by a supplier.  Consequently further undercutting the need requirement.

Furthermore, there was no consideration of climate warming. That’s what will require less gas to heat homes in the future.

So NG speculates that there might be an outage on a supply line on the one particular day when the average temperature is 5° F. Although NG provides no factual data about the likelihood. You know: of an outage. Outages cannot be presumed.

Nor does the NG provide factual data concerning its history of outages. Furthermore, even possible interruptions of supply from Dominion Energy Transmission Inc. or of any of its suppliers is not publicly available information.

Without any factual data about past outages or interruptions of supply what can be calculated. Even projections from NG about such in the future. Bottom line, the PSC cannot make a determination that outages could occur in the future. All such data must be present in the application for review by the public.

Without this data, a PSC determination approving the pipeline would be arbitrary and capricious.

In addition and a project of this magnitude, which intrudes on the Hudson River. For it runs counter to efforts to move our State to clean energy. So it cannot be authorized. Also the cost should not be passed on to ratepayers. All moreover and to merely to try to solve a “projected” 1.1% gap in peak hour usage. Especially when it has not been shown that conservation efforts would be impossible to solve that gap. 

There are so many environmental and public safety reasons. In conclusion and all that should be compelling enough for PSC to reject this application. However at the heart of this application is a lack of research and information provided by National Grid.

written by,

Chelsea Zantay
Averill Park, New York 12018
submitted by,
Robert Connors
Stop NY Fracked Gas Pipeline
1409 County Rte 5
Canaan, NY 12029