The Honorable Andrew M. Cuomo
Governor of New York State
NYS Capitol Building
Albany, New York 12224
January 28, 2014
Dear Governor Cuomo:
We would like to express our sincere and deep appreciation for your prohibition of high volume hydraulic fracturing in New York State, based on the public health concerns identified by Commissioner Zucker and the economic reasoning of Commissioner Martens.
This bold decision displayed great leadership, foresight and a deep commitment to safeguard the health and safety of all New York citizens. We, the undersigned organizations and individuals, request that the same reasoning and the same courageous leadership that went into banning horizontal drilling serve to reject any and all state support for the proposed CPV Valley Energy Center. It is a 650 MW gas-fired power plant project in Orange County that now seeks to secure power purchase agreements and other guarantees from state entities.
We oppose the project for the following reasons:
1. This project does not meet any reasonable clean energy standards. It would be a new source of over 2.1 million tons of CO2 emissions annually. Much of the fuel would derive from high-volume fracking wells in Pennsylvania. This fracked gas would be backed up by a diesel-fuel tank of nearly a million gallons. The global warming potential (GWP) of this project must be calculated from the full life cycle of the gas — from wellhead to power plant, assessing combustion as well as the fugitive methane that leaks or is purposely vented during the extraction, processing and transportation of the gas.
2. According to the U.N. sponsored Intergovernmental Panel on Climate Change, methane has a GWP 86 times that of CO2 over a 20-year time frame. The expected life of this project is thirty years , well past the climate tipping point. A more recent IPCC report concludes that, to avert climate catastrophe, greenhouse gas levels must be significantly reduced by 2020, a mere five years from now! These and other reports indicate that we must transition away from fossil fuels entirely. The notion that gas is a bridge fuel is not supported by the science.
The climate crisis is an economic as well as environmental threat given the extensive property damage resulting from super storms, such as Sandy, that are caused by rising temperature. In fact, with the current trajectory, by mid-century, climate change is expected to cost New York State 10 billion dollars annually.
3. The CPV project is highly controversial because many environmental and public health concerns raised by local residents were never addressed during the State Environmental Quality Review Act review, which was led by the local town board (problematic in its own right). The project is located on pristine land of “agricultural significance,” unusually rich in cultural and archeological resources. Indeed, the New York State Department of Environmental Conservation identifies it as a Critical Environmental Area (CEA). It sits on the edge of New York’s famed black-dirt region, home to many specialty farms, orchards and vineyards. The project site includes designated wetlands, endangered species habitat and farmland of historical significance.
Most disconcerting is that it would be in close proximity to residential neighborhoods and schools, including a public housing project directly adjacent to the site. Exposure to particulate matter and volatile organic compounds has long been documented to increase cardiovascular, respiratory and cancer risks. This is a massive industrial facility that simply does not belong in such a sensitive area.
Now CPV seeks to burden the public further by expecting taxpayers and ratepayers to fund its construction and operation. This is also contrary to representations made by CPV during Public Service Commission proceedings that the project would be funded and secured by private financing arrangements.
4. This project is not needed. New York State currently has excess electric power generation capacity, only utilizing approximately 41% of existing generation capacity. As identified in the New York Independent System Operator Power Trends 2013 Report and supported by the NYS Energy Plan, there is no current or anticipated shortage of electrical power supply in our state. While there is an imbalance between upstate and downstate energy supplies, the New York State Energy Highway Blueprint Initiative would implement transmission upgrades that will remedy the present delivery congestion.
Any future needs must be met by 100% renewable energy choices. As the cost of solar and wind energy continues to decrease dramatically, the idea of spending 900 million dollars on polluting fossil fuel infrastructure burdened with heavy externalities is untenable and irrational.
5. Finally, New York State’s principled and informed position on fracking must logically be extended to ban the use of fracked gas for both material and moral reasons.
(a) The air quality and water impacts identified by the studies cited by Commissioner Zucker cannot be stopped at the Pennsylvania/NY border.
(b) If fracking is not safe for New Yorkers it is not safe for our neighbors in PA. Increasing our dependence on and use of fracked gas would increase regional, as well as local, environmental and public health risks. It would also make us complicit in the suffering and harm of our neighbors.
In conclusion, the CPV project is not consistent with New York’s vision of a clean, sustainable energy future. It would create enormous adverse environmental impacts and jeopardize public health. It seeks to transfer all of the costs and risks onto ratepayers and taxpayers. It would require an extensive infrastructure network that would accelerate the climate crisis and displace investments in renewable energy. For these reasons, we the undersigned urge you to reject consideration and approval of the CPV Valley Energy Center project.
Cc: The Honorable Audrey Zibelman
New York State Public Service Commission
Three Empire State Plaza
Albany, NY 12223-1350
350MA-Berkshires Arnold Piacentini, Coordination Team Member
Shira Wohlberg, and Anne O’Connor
Judy Eddy, Coordinator No New Fossil Fuel Infrastructure/Pro-Renewables Campaign
Artisan Kitchen and Bath
David Drugmand, Construction Supervisor
Christopher Derby Kilfoyle, President
Bread Eaters of Beaver
Russell Honicker, Baker
Breathe Easy Susquehanna County (BESC)
Rebecca Roter, Chairperson
Catskill Citizens for Safe Energy
Heidi Gogins, Director
Center for Environmental Health
Leigh Scudder, Intern
Citizen Action of NY
Kat Fisher, Lead Organizer
Citizens Environmental Coalition
Barbara Warren, Executive Director
Clean Air Council
Matt Walker, Community Outreach Director
Harriet Shugarman, Executive Director
Community Environmental Health
Concerned Residents of Oxford NY
Mina Takahashi, Founding member
Damascus Citizens for Sustainability
Ruth Hardinger and B. Arrindell, Director
Delaware Action Group
Carole Marner, Founding Member
Food And Water Watch
Eric Weltman, Senior Organizer
Julia Walsh, Director
SPAN Oann Myersj
Gas Free Seneca
Yvonne Taylor, Co-Founder
Global Community Monitor
Jessica Hendricks, Senior Program Manager
Grassroots Environmental Education
Patti Wood, Executive Director
Howie Hawkins, 2014 candidate for NY Governor
Hudson River Sloop Clearwater, Inc.
Manna Jo Greene, Environmental Director
Hungry Hill Air Patrol, Hancock, NY (Compressor Station)
Gerald J Faucher, Organizer
Jamie Tousant, Levi Tousant, Malissa Williams
Madcopreservation Andrea Sutherland , DeRuyter NY
Madison County Neighbors for Environmental Preservation
Liz Haskins, Concerned Citizen
Massachusetts PipeLine Awareness Network
Kathryn Eiseman, Director
Myersville Citizens for a Rural Community
Tammy Mangan and Ted Cady, Secretary
Buck Moorhead, Director
People For a Healthy Environment
Protect Orange County
Deb Slattery, Director
Ramapo Lenape Indians
Joseph Liporace Jr
Ramapough Lenape Nation
Jack Anderson, Tribal Counsel Member
Roseland Against Compressor Station (RACS)
SACRED (Sullivan Area Citizens for Responsible Energy Development)
Wendy Robinson, Co-founder
Sane Energy Project
Clare Donohue, Program Director
Save Native Sites
Judy Abbott, Gallery owner/ Artist
Second Home Solution
Patricia Drugmand, Property Manager
Sierra Club Atlantic Chapter
Randolph Hurst, Ramapo/Catskill Group Conservation Committee Chairman
Stop the Algonquin Pipeline Expansion
Susan Van Dolsen, Co-founder
Stop The Minisink Compressor Station (StopMCS)
Pramilla Malick, Founder
The Mothers Project
Angela Monti Fox, Director
Edward Nardi, Citizen
Mina Hamilton. Writer
Mary Beth Egan, NY taxpayer
Hope Sandrow, Artist
Natalie Jean Tyner
Bernard Handler, DCS, steering committee
Sandra Kissam, Orange County Citizen, Newburgh, NY
Erika Myers, Private Citizen, Historic Home and land owner