The Public Service Commission will be accepting public comments on National Grid’s plan until May 1, 2020.

Email comments to the Secretary of the NY State Dept. of Public Service’s Secretary:

Hon. Michelle Phillips:  secretary@dps.ny.gov

National Grid’s webpage has information about submitting comments, too – See:  https://ngridlongtermsolutions.com

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From National Grid’s website:  There are multiple ways to voice your opinion

The Company held a series of public meetings in March, to provide the public and our customers with an opportunity to review each of the options, ask questions of subject matter experts, and make public feedback statements. The transcripts for the public meetings are available via links below. The series of public and virtual meetings is now complete. Whether you attended a public meeting or not, there is an equal opportunity to have your voice and opinion heard and reflected prior to any final decisions being made. There is still an opportunity to learn about the long-term gas capacity options and provide feedback up until 5/1/20 in any of the following ways:

1. Complete the survey on this site
2. Provide feedback directly to the state of New York via the following link: NYS DPS comment form
3. Submit comments to the Department by email to the secretary at secretary@dps.ny.gov
4. Mail your comments to the Hon. Michelle L. Phillips, Secretary to the New York State Public Service Commission, Three Empire State Plaza, Albany, New York, 12223-1350
5. You can also provide comments over the phone using the Department’s Opinion Line by calling 1-800-335-2120 (see here for more info)

After all the feedback is collected and reviewed, the Company will issue a supplemental report that summarizes and includes public and customer input — all to enable an agreed long-term solution(s) with New York State by June 2020. This timeline will enable the solution(s) to be in place and in operation by the winter of 2021/2022. 

Re:  Case #s 19-02328 and 19-G-0678

Proceeding on Motion of the Commission to Investigate Denials of Service Requests by National Grid USA, The Brooklyn Union Gas Company d/b/a National Grid NY and KeySpan Gas East Corporation d/b/a National Grid

NESE is Not Needed – Reports

Links to reports showing that the claim that National Grid “needs” the gas from NESE is false:

• Institute for Energy Economics & Financial Analysis (April 2020)

https://ieefa.org/wp-content/uploads/2020/04/Proposed-NESE-Gas-Pipeline-a-Bad-Bargain_April-2020.pdf

Proposed NESE Gas Pipeline in New York: A Bad Bargain for Ratepayers and Taxpayer- 

Modern Energy Planning Would Be a Better Approach.   Suzanne Mattei, IEEFA Energy Policy Analyst, Tom Sanzillo, IEEFA Director of Finance, & Margaret Stix, President, Lookout Hill Public Policy Associates 

• Synapse (4-6-20)

https://www.synapse-energy.com/project/assessment-national-grids-long-term-capacity-report

 Assessment of National Grid’s Long-Term Capacity Report – Natural gas capacity needs and alternatives.   Prepared for the Eastern Environmental Law Center by Kenji Takahashi, Asa Hopkins, PhD, John Rosenkranz, David White, PhD, Shelley Kwok, Nate Garner

• Energy Futures Group (3-9-20)

https://energyfuturesgroup.com/wp-content/uploads/2020/03/Critical-Elements-in-Short-Supply_EFG_March-9-2020-FINAL-posted.pdf

Critical Elements in Short Supply: Assessing the Shortcomings of National Grid’s Long-Term Capacity Report.   Prepared for: 350.org and 350Brooklyn by David G. Hill, Ph.D., Chelsea Hotaling & Gabrielle Stebbins, of Energy Futures Group 

• Rocky Mountain Institute (2-28-20)

New York Can Meet Its Energy Needs without a New Pipeline

New York Can Meet Its Energy Needs without a New Pipeline.  By  Mike Henchen & Sherri Billimoria

COMMENT POINTS

from:  STOP THE WILLIAMS PIPELINE NY (NESE PIPELINE) CAMPAIGN ORGANIZED BY 350BK, SURFRIDER NYC CHAPTER, SANE ENERGY PROJECT, FOOD & WATER ACTION, NEW YORK COMMUNITIES FOR CHANGE, 350, AND ROCKAWAY BEACH CIVIC ASSOCIATION.

Background:

National Grid, the corporate utility covering part of NYC and Long Island has put forth a long-term energy plan to end their widely condemned moratorium that includes  1) off-shore liquefied natural gas terminal (LNG)  2) on-shore LNG import ports  3) fracked gas trucks  4) the Williams NESE pipeline.

There’s overwhelming evidence that there’s no need for the gas that would be transported by the Williams NESE Pipeline or any of National Grid’s fracked gas proposals.

Despite a growing number of New Yorkers getting sick, National Grid is going full steam ahead pushing these disastrous fracked gas projects.  Instead of delaying the process so people can give public comment in person, National Grid has moved to undemocratically designed virtual “public meetings” that have allowed for them to skip over questions and comments and that many folks don’t have the technological capabilities to join.

Any proposal that includes fracked gas goes against the Climate Leadership and Community Protection Act and risks creating stranded assets that ratepayers will be stuck paying for.

All of National Grid’s fracked gas proposals should be turned down. These proposals include

• Offshore Liquified natural gas (LNG) terminal 
• Onshore LNG terminal
• Compressed natural gas (CNG) trucks
• Offshore LNG floating barges
• North Brooklyn (Metropolitan Reliability Infrastructure) pipeline 
• Staten Island pipeline

A disgraced utility like National Grid should not be in charge of New York’s energy future. It cares about profits, not people, and wants more fracked gas infrastructure to perpetuate its outdated business model, not because it needs the gas. 

• National Grid is a multi-billion-dollar monopoly that makes a guaranteed rate of return from building fossil fuel infrastructure, which ratepayers pay for through higher bills.  WE pay for pipelines so that THEY can profit. 
• Because National Grid makes its money off of gas infrastructure and gas customers, it has little incentive to do what is best for the climate and New Yorkers and push for renewable solutions.  

National Grid’s new report showing the need for more infrastructure like the Williams NESE pipeline is full of omissions, skewed data, and is essentially propaganda. 

• The entire 116-page report is based on grossly inflated gas demand projections that do not match up with the figures provided by the Energy Information Administration.
• National Grid’s demand projections also fail to reflect the utility’s own historical trends, which show gas use to be declining.
• The report downplays the contributions that renewable heat pumps (which double as air conditioners), demand response technology, efficiency, and other measures could make in reducing demand, while failing to mention whether it could offset pipeline demand through innovations in the power sector, which accounts for 42% of NG gas sales on Long Island and 20% in NYC. 
• The report doesn’t mention that ratepayers would bear the costs of these projects. 
• NG’s report includes pipeline alternatives such as offshore LNG merely to make the pipeline option look better. Activists successfully defeated the Port Ambrose offshore LNG terminal in 2015, and the oil and gas would be foolish to attempt this again.  

National Grid’s report grossly understates the NESE pipeline’s climate impacts. 

• National Grid claims that the NESE pipeline could achieve significant greenhouse gas savings by preventing customers from using dirtier fuels. Yet many of these assumptions have already been disproven, and NG’s economic and customer growth projections are highly suspect and lack citations that would allow further scrutiny.  
• National Grid bases its greenhouse assessment of NESE on a study by MJ Bradley that uses discredited data on methane leakage and the wrong timespan for considering its warming potential (100 years as opposed to 20) while burying the correct information in an appendix.  
• A new report from Energy Futures Group shows that, to adhere to state climate law, 85% of the NESE pipeline gas would need to be avoided. Fracked gas is, after all, the main driver of carbon emissions and the reason state and local emissions goals are not being met. (Source). 

National Grid’s report also says nothing about the financial risks of the pipeline to ratepayers.   

• NG doesn’t mention the chances of the NESE pipeline becoming a stranded asset. NESE would be expected to last until around 2070. Yet state climate law mandates net zero emissions by 2050, and Local Law 97 will reduce big building emissions 40% by 2030. Gas use will plummet during that time, making the pipeline obsolete well before its intended retirement date.
• The Williams NESE pipeline would cost ratepayers roughly $1.4 billion dollars, and all for a project that would likely only be in service for a decade at most. 
• National Grid fails to include externalized costs in its assessments. The social costs of contributing to the climate crisis and the environmental costs of building a 23-mile pipeline through New York Harbor would be significant and yet are entirely left out.  

Non-pipeline renewable solutions can—and must—handle the job!  

• A new report from Energy Futures Group shows that when National Grid’s demand projections are adjusted to the more reasonable EIA figures, 85% of the gas in the Williams NESE pipeline would be unneeded, leaving a mere 15% to be met by renewable solutions.  
• The paper also shows that when aggressively implemented, renewable non-pipeline solutions alone could offset 88% of the capacity of the NESE pipeline. 
• The renewable future is here. Regulators and politicians will either be leaders and usher it in or cave to corporate interests and keep us chained to the energy of the past. The choice is theirs.

Now is the time for the PSC to take a firm stance and work toward the required clean, renewable energy future for us rather than support and/or turn a blind eye to misleading (at best) information provided by National Grid & those they hired to promote their interests.  We know the truth of climate change impacts & should not need to make choices that will further harm our health, safety & environment when there are less expensive & cleaner options than the NESE Project for our future energy needs.

Comment 1:  National Grid’s Exploitation of COVID-19

By continuing to hold virtual “public meetings” during the COVID-19 outbreak, National Grid is taking advantage of a crisis to push through wildly unpopular projects.

• New Yorkers are struggling to stay healthy, care for kids and sick relatives, process news, and stay sane during the worst public health crisis in a century. This is hardly the time for meetings pitching fracked gas infrastructure that New York doesn’t need and that New Yorkers don’t want.  
• This is disaster capitalism—exploiting a crisis in order to push through lucrative projects with as little friction as possible. National Grid would profit off the infrastructure it is pitching.
• National Grid is also exploiting this crisis by continuing to work on the widely opposed MRI Pipeline in North Brooklyn, rushing through construction at a time when community members—who, before social distancing, had been rallying against the project every weekend—cannot show up to shut it down.

The switch from public meetings to virtual meetings is having a silencing effect on the community.  

• By moving to virtual meetings, National Grid is robbing the public of the chance to show its true power as a collective, which National Grid is clearly scared of.
• At the first virtual meeting, several participants were unable to ask questions and comment, despite trying multiple times, yet this wasn’t apparent in the virtual setting. Had the meetings been in person, this would have been clear to the public.  
• National Grid also concealed the names and numbers of attendees once the number reached 160, preventing attendees and the press from knowing the extent of the turnout.  

National Grid’s virtual interface is laughably clunky and provides an undemocratic way to access the meetings.  

• Users are required to download a browser extension just to join the meeting and see the videos and presentation, then dial in on their phones to hear the meeting audio.
• This discriminates against New Yorkers who might not be able to figure out the technology or who have no access or means to acquire multiple devices.
• National Grid didn’t provide links to meeting access early enough before the first two events, which goes against best practices and prevents people from circulating information about the meetings beforehand.
• There is also no video option allowing to see the public, which is cowardly on the part of National Grid and robs the public of an important mode of expression.

National Grid has proven to be the real public health menace, exploiting one public health crisis for projects that would only contribute to another.

• National Grid is taking advantage of COVID-19 to push fracked gas, which is exacerbating the climate crisis—a public health crisis orders of magnitude greater than COVID-19 will ever be.
• By continuing to work on the MRI Pipeline, National Grid is subjecting its own workers and the surrounding community to the virus, once again putting profits over people.

As a regulator tasked with protecting New Yorkers, the PSC must stop enabling National Grid to exploit this crisis. You must shut these meetings down, and stop giving a platform to a monopoly utility that so clearly puts profits over people!

Comment 2:  Tell the PSC: National Grid’s fracked gas proposals fail the climate test

National Grid’s business model is dependent on fracked gas expansion and their long-term energy proposals show they are willing to sacrifice a livable planet to keep that business model alive.

Last year both New York City and State passed groundbreaking climate legislation requiring a dramatic reduction in greenhouse gas emissions. National Grid completely ignored those laws by proposing fracked gas projects like the Williams NESE pipeline and large and small scale liquefied natural gas (LNG) in their long-term energy plan.

A new white paper from Energy Futures Group found that in order for the Williams  pipeline to adhere to the Climate Leadership and Community Protection Act, 95% of its gas would have to remain unburned.

Yet for the past three nights, during a public health crisis, National Grid has had the audacity to present the Williams Pipeline as “neutral” for the environment during their virtual “public meetings”.

They also presented options for LNG barges, which New Yorkers overwhelmingly campaigned against and defeated in 2015.  LNG is even worse for the climate because liquefying gas through super cooling is a very energy intensive process on top of the damage gas extraction and piping already creates.

The truth is there is no safe way to transport or burn fracked gas when it comes to our climate and it’s an insult to every New Yorker who fought for the CLCPA and Local Law 97 in NYC for National Grid to be proposing fracked gas infrastructure expansion in 2020.

National Grid’s fracked gas proposals completely defy state climate law

• Last Spring, New York State passed the Climate Leadership and Community Protection Act (CLCPA), which mandates that the state emit no more than 35 million metric tons of carbon-dioxide-equivalents by 2050 (15% of what it emitted in 1990).  
• Yet the gas National Grid supplied to its customers in 2015 yielded 70 million metric tonnes of carbon-dioxide-equivalents when burned—twice the amount required by the CLCPA.
• The Williams NESE pipeline would increase the gas supply in New York by 14%. Even when combined with renewable solutions, there is clearly no room for more fracked gas in the CLCPA.
• A new white paper from Energy Futures Group affirms this, showing that, in order for the Williams NESE pipeline to adhere to the CLCPA, 95% of its gas would have to remain unburned.

Much of the data that National Grid uses in its report is either discredited or used in misleading ways

• National Grid claims that more fracked gas infrastructure will help reduce emissions by preventing customers from using dirtier fuels. Yet all of the conversions from the really dirty #6 oil in New York City were completed by the end of 2015.
• National Grid’s report also cites a paper by MJ Bradley that uses the wrong data on methane. Its calculations relied on methane’s 100-year warming potential rather than its far more potent (and relevant) 20-year potential, which is 86 times that of C02.
• The EJ Bradley paper also uses the Department of Energy’s outdated data on methane leakage rather than the EDF figures, which show that methane’s upstream contributions to global heating are 24% higher than previously thought. Moreover, Robert Howarth of Cornell has recently published evidence that the upstream leakage of fracked gas is on the order of 12%, not the 3% figure used by the EPA.

The report also foregrounds implausible solutions like hydrogen and “renewable gas”

• National Grid is pitching both of these solutions only because they could be used with its existing and proposed infrastructure, allowing it to evade arguments that its pipelines could become stranded assets.
• In reality, neither are plausible near-term solutions, both because of cost and limited impact.

The entire premise of National Grid’s report and public meetings—that an investor-owned gas company’s energy proposals should be taken seriously during a climate crisis—is absurd.

• National Grid’s business model is based entirely around fracked gas. They have zero incentive to truly explore renewable energy.
• In the service area under consideration, National Grid loses market share when its customers shift from gas to more efficient electric heating. National Grid therefore has a financial incentive to discourage people from moving off of gas.
• A new report, issued by an independent monitor overseeing National Grid’s post-moratorium activities, quotes senior National Grid executives saying that the utility historically has not “actively try[ied] to get people to electrify” in the Service Territory because it is not “our business.” (Source, pg.11)

Comment 3:  No Need for the Gas from the Proposed NESE Project

When the Williams NESE Pipeline was temporarily denied last year, National Grid claimed there would be a gas shortage and began taking customers hostage with a widely condemned moratorium. Now they’ve included this claim in their long-term capacity report.

We don’t buy it and never have.

There’s overwhelming evidence that there’s no need for the gas that would be transported by the Williams Pipeline. A newly released report shows that National Grid’s gas growth projections don’t match those from the U.S. Energy Information Administration and are highly inflated.

This means there’s no need for the Williams Pipeline or any of National Grid’s fracked gas proposals in their long-term energy plan.

And the good news is we know renewable solutions can do the job National Grid is claiming we need fracked gas for.

When aggressively deployed, renewable, non-pipeline solutions such as energy efficiency measures, demand response, electric heat pumps (which double as air conditioners) could offset as much as 88% of the capacity of the NESE pipeline.

The Lack of Need for the Williams NESE Pipeline

A new whitepaper by Energy Futures Group refutes the findings of National Grid’s recently released report on long-term gas capacity, which continues the disgraced utility’s efforts to push for the Williams NESE pipeline in New York Harbor.

There is overwhelming evidence that the gas that the Williams NESE pipeline would bring isn’t needed.  

• Suzanne Mattei, a former regional director with the DEC, has disproven National Grid’s initial justification for the pipeline: that more gas is needed to allow customers to convert their boilers from oil to gas. In fact, the majority of relevant boiler conversions happened years ago. (Source)
• The report also emphasized that gas demand in our region is flat or negative. At least four separate agencies and studies have demonstrated this, citing increases in energy efficiency and the use of renewables as reasons. (Source, pg.20).

A new whitepaper from Energy Futures Group (EFG) reaffirms these claims, showing that National Grid’s demand projections are grossly inflated.  

• In its new report on long-term capacity, National Grid claims that peak demand is expected to increase by 0.8–1.1% per year at the bare minimum, which equals 8–11% growth in 10 years (Source, pg.7). Yet the U.S. Energy Information Admin. predicts an increase of only 1.6% over the entire next decade. (Source).
• National Grid’s demand projections are also inconsistent with its own historical data, which show that demand has slowed significantly in the last six years. (Source, pg.4)
• National Grid’s filings with the New York PSC bear this out, showing that, in 2017, National Grid used 35% less gas than anticipated even as it added 12,000 more customers than it had predicted adding.
• There are also mistakes in the report. On pg.2 of the report’s technical appendix, National Grid’s calculations of gas demand per customer are off by an entire decimal point, significantly inflating demand.

Crucially, the EFG paper finds that renewable, non-pipeline solutions could offset the need for 88% of the NESE pipeline capacity, and that adjusted demand figures alone could offset 85% of the gas.  

• When demand projections are adjusted to the more reasonable ones from the EIA, 85% of the NESE pipeline gas would be offset, leaving a mere 15% to be met by renewable solutions. (Source, pg.4)
• When aggressively deployed, renewable, non-pipeline solutions such as energy efficiency measures, demand response, electric heat pumps (which double as air conditioners) could offset as much as 88% of the capacity of the NESE pipeline. (Source, pg.4)
• The Rocky Mountain Institute has also scrutinized National Grid’s report and found that the pipeline is not needed.

By claiming it needs more gas, National Grid is exploiting the fact that no federal or state regulator has assessed the real need for this project, nor possible alternatives to it. The real reason it wants the pipeline is to secure its business model.

• No federal or state regulator has fulfilled the mandate to explore practicable alternatives to the pipeline. (Source). FERC in particular, in its environmental impact statement, ignored the NEPA requirement that it explore these alternatives, using an overly restrictive definition of the project to claim that renewable solutions couldn’t achieve the same ends as gas (Source, p.3-1)
• Both National Grid and Williams are taking advantage of this to secure the pipeline as a revenue stream. Williams will make a guaranteed rate of return (14%) on this project, regardless of whether or not it is needed.
• Because National Grid mostly supplies gas and not electricity in the relevant service area, it loses market share when its customers shift from gas to electric heating. National Grid therefore has a financial incentive to discourage people from moving off of gas.
• Another new report, issued by an independent monitor overseeing National Grid’s post-moratorium activities, quotes senior National Grid executives saying that the utility historically has not “actively tr[ied] to get people to electrify” in the Service Territory because it is not “our business.” (Source, pg.11)

State and local climate legislation will drastically curtail gas use in the next decade, further reducing need while creating the risk of stranded assets.

• The energy efficiency and widespread electrification required by New York City’s Local Law 97, which mandates that big buildings reduce emissions by 40% by 2030, and the state’s CLCPA, which mandates net zero emissions by 2050, will drastically reduce gas use over the next decade, making the pipeline obsolete well before its intended date of retirement.
• Lower-income ratepayers, who have less ability to shift to electric heating/hot water, will be left paying for these assets, which is expected to cost $1.4 billion.

New York Mayor Bill de Blasio just issued an executive order that will eventually stop all new fossil fuel infrastructure. This will further restrict what can be done with the pipeline’s gas, and will only make the environment for this pipeline more hostile.

Comment 4: Tell the PSC that NESE Is Not a Viable Option

National Grid’s report on their long-term energy plan states that “community impacts” of NESE “would be minimal with the majority of construction happening offshore.” We know that is not true particularly for coastal communities, including Staten Island, Coney Island, and the Rockaways.

National Grid’s report also tried to downplay the climate impacts of the Williams Pipeline and the threat to the health and safety of the harbor. 

Background:

One of the options contained in National Grid’s Long-Term Capacity Report is Williams’ proposed Northeast Supply Enhancement project (NESE).  National Grid has contracted with Williams for this over one billion dollar project.  NESE – which has already been denied by the New York State Department of Environmental Conservation twice, most recently in May 2019 – should not be an option for downstate New York’s energy needs for many reasons, including:

The Cost of NESE Will Be Passed to National Grid Customers

• The burden of paying for this over one billion dollar project would be borne by National Grid’s customers.  
• The Report fails to mention the likelihood of NESE becoming a stranded asset. National Grid, which would pay for the pipeline over 15 years, wouldn’t make its last payment until around 2037 at the earliest. Ratepayers might well be absorbing those costs for years after that. Yet Local Law 97 will reduce big-building emissions 40% by 2030 and 80% by 2040, drastically cutting gas use. The pipeline would hardly be needed by then.
• NESE will cost ratepayers roughly $1.4 billion dollars and for a project that will likely only be in service for a decade at most.

NESE Threatens the Health of NY Harbor and Its Inhabitants

• This pipeline project threatens the health of NY Harbor – which is the healthiest that it has been in decades due to stricter environmental laws – and the animals that inhabit it.  
• As concluded by the DEC in its denial, the installation of this pipeline would result in the release of dangerous toxins, including mercury and copper, into NY Harbor.
• The DEC also found that pipeline construction would destroy any benthic community, such as clams and oysters, in its path.
• The pipeline construction – which would cause release of toxins, increased turbidity, vibrations from pile driving, and increased amount of large vessels in the Harbor – threatens countless other marine species, including the endangered Atlantic sturgeon, winter flounder, sea turtles, and humpback whales, which have made a return to the the Harbor in the last several years.
  

National Grid’s Claim that Community Impacts of NESE Will Be Minimal Is False and Misleading

• The Report states that “community impacts” of NESE “would be minimal with the majority of construction happening offshore.” This is a completely false and misleading statement. NESE will, in fact, have serious impacts on New York City communities, particularly the coastal communities, including Staten Island, Coney Island, and the Rockaways.
• Super Storms like Sandy – which destroyed NYC’s coastal communities in 2012 – are a result of climate change. As the DEC concluded, this pipeline will contribute towards climate change.
• The benthic communities are natural water filterers and storm barriers, which help protect the coast from storm surge. As the DEC concluded, this pipeline would destroy the benthic communities in its path.
• The ocean is the backyard to coastal communities of New York City and is enjoyed by many more New Yorkers. As the DEC concluded, the pipeline will release toxins, such as mercury and copper, into the ocean where we swim, surf, and fish, thereby threatening human health.

NESE Is Not Needed

• National Grid has claimed all along that NESE is needed because New Yorkers were switching from oil to gas and more would be doing so in the future. This claim was based, in large part, on the fact that New York City regulations mandated the phase-out of No. 6 fuel oil, which would lead to an increase in conversions. However, in actuality, these mandated conversions already occurred by the end of 2015.  
• The data set forth in the Report is based on unsubstantiated assertions or unwarranted assumptions, as is pointed out by a recent paper by Energy Futures Group entitled “A Framework for Critical Analysis of National Grid’s Long-Term Natural Gas Needs Assessment.” For example, National Grid claims that peak demand is expected to increase by 0.8–1.1% per year at the bare minimum, which equals 8–11% growth in 10 years. Yet the U.S. Energy Information Administration predicts an increase of only 1.6% over the entire next decade.
• There are also mistakes in the Report. For example, on page 2 of the Report’s technical appendix, National Grid’s calculations of gas demand per customer are off by an entire decimal point, significantly inflating demand. National Grid has since corrected this error, but only after being called out about it at one of their public meetings.
• National Grid’s demand projections also fail to reflect the utility’s own historical trends, which shows gas use to be declining.  
• The EFG report shows that when National Grid’s demand projections are adjusted to the more reasonable EIA figures, 85% of the gas in NESE would be unneeded, leaving a mere 15% to be met by renewable or energy efficiency solutions.
• Another recent report, from Synapse Energy Economics, shows that National Grid is likely to have a surplus, not a deficit, of gas by 2035. The report reaches this conclusion by showing how National Grid overestimated the future rate of oil to gas conversions, failed to account for energy efficiency savings required by NYSERDA, and did not properly account for impacts on demand by Local Law 97, among other things.

NESE Will Contribute Towards Climate Change and Runs Contrary to the CLCPA

• NESE would carry as much as 400,000 dekatherms of fracked gas into the region each day. Fracked gas is largely methane, a greenhouse gas 86 times more powerful in the short term than carbon dioxide. When just 3.2% of methane leaks – and gas infrastructure is known to leak as much as 11% – methane is as bad for the climate as burning coal.
• The DEC also noted that 99,781 tons of carbon dioxide-equivalent emissions (the equivalent of burning 50,000 tons of coal) would be released from the construction of the project alone.
• The EFG report shows that, to adhere to the recently passed Climate Leadership and Community Protection Act, 95% of the NESE pipeline gas would need to be avoided.
• In its Report, National Grid bases its greenhouse assessment of NESE on a study by MJ Bradley that uses discredited data on methane leakage and the wrong time span for considering its warming potential (100 years instead of 20 years) while burying the correct information in an appendix.

Comment 5:  Untrustworthiness and Irresponsibility of National Grid

Last year, the New York State Department of Environmental Conservation (DEC) listened to science and the people of New York and temporarily rejected the Williams fracked gas pipeline.

But instead of taking the pipeline denial as an opportunity to build the renewable energy future we need, National Grid began taking ratepayers hostage with a widely condemned moratorium.

The Public Service Commission (PSC) ordered National Grid to end their moratorium and pay a $36 million penalty for “its abuse of its customers and the adverse economic impact they have caused.”  

National Grid’s irresponsible actions during the moratorium aren’t an isolated incident. Before the moratorium a PSC investigation found 1,500 violations of gas safety regulations relating to gas infrastructure work in their service territories of Queens, Brooklyn, and Long Island.

National Grid also failed to halt construction of their controversial North Brooklyn Pipeline until March 26, 2020, well after the COVID-19 crisis had fully hit NYC.

It took the local community and ratepayers organizing and expressing their serious concerns, including many verbal comments at the National Grid virtual public meetings in March, to get the company to suspend construction.

We need a utility that will act in the public interest, not a company who continues to push for rate hikes to fund fracked gas infrastructure by any means necessary.  

Background:

One of the options contained in National Grid’s Long-Term Capacity Report is Williams’ proposed Northeast Supply Enhancement project (NESE). National Grid has contracted with Williams for this over one billion dollar project. NESE – which has already been denied by the New York State Department of Environmental Conservation twice, most recently in May 2019.

Instead of taking the pipeline denial as an opportunity to build the renewable energy future we need, National Grid began taking ratepayers hostage with a widely condemned moratorium. The Public Service Commission (PSC) ordered National Grid to end their moratorium and pay a $36 million penalty for “its abuse of its customers and the adverse economic impact they have caused.”  

National Grid’s Abuse of Ratepayers through Self-Imposed Moratorium  

• National Grid is required to release this Long-Term Capacity Report and hold this public participation process because it abused ratepayers last year. It is not doing any of this for public good or because it actually values public feedback.
• Last year, National Grid held its own customers hostage over the Williams pipeline. In the wake of the NYS Department of Environmental Conservation’s denial of the pipeline in May 2019, National Grid issued a self-imposed moratorium on all new gas connections until the pipeline was approved. This severely hurt small businesses, new home owners, and other ratepayers.
• National Grid also directly asked its ratepayers to support the pipeline, without involving the Public Service Commission. In a misleading email sent on July 8, 2019 entitled “Natural gas supplies are at risk in downstate New York,” the company directed people to an online petition to Governor Cuomo and the DEC in support of the Williams pipeline. This was an outrageous and inappropriate request given that this pipeline would generate huge profits for National Grid while raising customer rates and contributing to the climate crisis.
• When it became apparent that the moratorium was bogus, Governor Cuomo accused National Grid of extortion and threatened to revoke its license to operate in NY State after which National Grid and Governor Cuomo/the PSC reached a settlement in November 2019. As part of that settlement, the company is required to pay a $36million penalty. Governor Cuomo stated “National Grid will pay a significant penalty for its failure to address the supply issue, its abuse of its customers, and the adverse economic impact they have caused.”

National Grid’s Poor Safety Record

• Public Service Commission proceeding, Case No. 17-G-0317
  • In July 2019, the PSC, after a lengthy and detailed investigation, commenced a penalty action against National Grid concerning 1,500 violations of gas safety regulations relating to gas infrastructure work in their service territories of Queens, Brooklyn, and Long Island.
  • In addition, the investigation found that National Grid failed to inspect work completed by its contractors during construction at sufficient intervals to ensure compliance and that it allowed the work to be completed by inspectors who were not properly qualified to do the work.
  • National Grid is also accused of failing to adequately train its pipeline installers, as required by state safety regulations. The PSC found that workers employed by National Grid’s contractor, which acted as National Grid’s agent with respect to the construction, were given the answers to the operator qualification exams.  
  • This proceeding is still pending.
• In January 2020, two utility workers were severely burned when a leaky gas pipeline operated by National Grid exploded into flames in Bensonhurst, Brooklyn.

National Grid Continued Construction of the North Brooklyn Pipeline during the COVID-19 Public Health Crisis

• In the midst of the COVID-19 public health crisis, National Grid continued construction of its Metropolitan Reliability Infrastructure (MRI) fracked gas pipeline, which is non-essential infrastructure, putting the health and safety of both the workers and the North Brooklyn community at severe risk.
• As of March 26, 2020, workers were seen on the construction site in close proximity to one another, putting themselves and local residents in danger by being in clear violation of suggested CDC social distancing practices.
• In light of ABC-7 reporting that a Consolidated Edison construction worker had tested positive for COVID-19, it is only appropriate for all New York utility companies to take the necessary precautions to protect their workers and the communities in which they work and stop all non-essential construction.
• National Grid finally halted construction of the MRI on March 26, 2020, well after the COVID-19 crisis had fully hit NYC. It took the local community and ratepayers organizing and expressing their serious concerns, including many verbal comments at the National Grid virtual public meetings in March, to get the company to suspend construction.

Comment 6:  Protect us from fracked gas Radioactivity

In January, Rolling Stone published a terrifying 20-month investigation on radioactivity in oil and gas.  Reporter Justin Nobel found that the fossil fuel industry has known for decades that radioactivity builds ups in their pipelines and infrastructure.

During recent virtual “public meetings” New Yorkers asked National Grid President John Bruckner if the company is testing for radon and what they were doing to ensure radioactive material isn’t building up in the infrastructure they use to deliver and store fracked gas.

Instead of answering the question Mr. Bruckner said he would not ‘debate the merit of radon’.  

Comments on National Grid’s long-term energy plan are due April 17. National Grid has proposed multiple false “solutions” including the Williams Pipeline that would transport and store more fracked gas from the Marcellus Shale, the most radioactive shale play in the country, in our communities.

Across the city people’s respiratory systems are being ravaged by the coronavirus.  We need to be making plans to retire dirty fossil fuel infrastructure, including fracked gas, to limit air pollution for survivors.

We know black, brown and indigenous communities are seeing more deaths right now because they have been bearing the brunt of fossil fuel air pollution for decades.  There’s no such thing as “clean” natural gas and we refuse to let National Grid use our money to bring more polluting fracked gas into our communities during this health crisis.

Background:

A 20 month-long investigation published in Rolling Stone found that the fossil fuel industry has known for decades that radioactive material is building up within their infrastructure as ‘scale’.

Despite delivering more gas from the highly radioactive Marcellus Shale, National Grid has no plans to test for radioactivity and refuses to answer ratepayer questions about the issue.

Things you might discuss in your comments:

A growing amount of National Grid’s gas is fracked from the Marcellus Shale, the most radioactive shale play in the country

• By 2016, 69% of all wells drilled in this country were fracking wells and that number has continued to rise.
• During its current rate case, National Grid testified that a growing percentage of the gas it delivers was produced through fracking in the Marcellus Shale.
• The proposed Williams NESE Pipeline for which National Grid is the sole purchaser of gas from would be transporting fracked gas from Pennsylvania’s Marcellus Shale into NYC.
• The Marcellus Shale in Pennsylvania has higher than average levels of uranium and thorium. These elements break down to form radium-226. Radium-226 breaks down into radon.
• Radon is the leading cause of lung cancer in non-smokers in the United States .

The fossil fuel industry has known for decades that radioactivity in gas is a problem yet National Grid has no plans to test for radioactivity

• A 20-month long investigation by Justin Nobel published in Rolling Stone in January 2019 found that the fossil fuel industry has known for decades that radioactivity is building up within their infrastructure as ‘scale’.
• Radon breaks down into lead-210 and polonium-210, which end up accumulating on pumps and filters in gas pipeline systems
• Because of the expansion of fracking production in the Marcellus Shale, gas in NYC is being transported an even shorter distance from a more radioactive shale play.
• During their current rate case (19-G-0309/0310) National Grid testified they are not testing for radon in the gas they deliver or for radioactive scale building up in their infrastructure.
• During virtual public meetings on the company’s long-term capacity plan (Case 19-G-0678)National Grid President John Bruckner failed to address the public’s questions about radioactivity and said he would ‘not debate the merit of radon’
• To ensure public safety, the PSC should require National Grid to do radon testing in accordance with New York State Assembly bill A102029.

Air pollution has been linked to higher coronavirus death rates, especially in black, brown and indigenous communities. We need to reduce air pollution by retiring dirty fossil fuel infrastructure, including fracked gas.

• A new study has found ‘Coronavirus patients in areas that had high levels of air pollution before the pandemic are more likely to die from the infection than patients in cleaner parts of the country’.
• Faux environmental justice groups have been trying to push for the Williams NESE Pipeline by presenting a false choice between oil and gas, claiming gas has less air pollution. But there’s no such thing as ‘clean’ fracked gas.
• To reduce air pollution we need to be retiring fossil fuel infrastructure, including fracked gas infrastructure, which is often located in low-income communities of color.
• The Climate Leadership and Community Protection Act protects environmental justice communities that have been disproportionately impacted from pollution and climate change from new fossil fuel infrastructure.
• In their report National Grid says they have not looked at the requirements of the CLCPA when determining the environmental impacts of their proposals.

Comment 7:  Renewables are cheaper and cleaner according to National Grid’s own report

The company’s “no infrastructure” option would combine energy efficiency, heat pumps, and demand response to meet new heating demand and avoid building the Williams NESE Pipeline or other gas infrastructure. As long as National Grid meets its other legally mandated energy efficiency targets to reduce demand for gas, the no infrastructure option would be less expensive than building the NESE pipeline.

Together, we have filed over 5,000 comments to oppose National Grid’s plan that pushes an overwhelming amount of fracked gas infrastructure projects that are nothing but a climate disaster.

But National Grid’s own report shows that we can meet the need for heat in downstate New York and avoid any new gas infrastructure!

The company’s “no infrastructure” option would combine energy efficiency, heat pumps, and demand response to meet new heating demand and avoid building the Williams NESE Pipeline or other gas infrastructure. As long as National Grid meets its other legally mandated energy efficiency targets to reduce demand for gas, the no infrastructure option would be less expensive than building the NESE pipeline.

Our allies at Renewable Heat Now! Drafted talking points on the National Grid options for refuting the need for a gas future in New York City and Long Island:

• Of the eight options considered by National Grid, seven are fossil fuel projects that would be built with gas utility customer money. How dare they! New York climate law requires a 40% reduction of greenhouse gasses by 2030 and the elimination of greenhouse gasses by 2050. How could National Grid propose to bring more methane gas into New York?
• The report shows that non-fossil-fuel options can meet the growing demand for thermal energy and contribute to the phase out of fuel oil within National Grid’s service area. It’s possible and it must be done!
• The “no infrastructure” option — which includes energy efficiency, demand response, and electrification through heat pumps — is the only legally viable option as well as one of the cheaper options discussed in the report. The “no infrastructure option” is $300 million cheaper than the NESE pipeline as long as National Grid meets its currently mandated energy efficiency targets. If National Grid misses those targets, then the company will need more expensive solutions to avoid fossil fuels. National Grid should not be allowed to miss those targets.

• National Grid stacked its analysis to favor gas infrastructure. The company failed to take into account the impacts of methane on the 20 year timescale now required by state law. It failed to quantify the other benefits that energy efficiency and heat pumps bring to households and communities. Weatherization and energy efficiency improve health, comfort, and affordability. Removing fossil fuel appliances makes homes safer and healthier by eliminating gas leaks, carbon monoxide exposure, and explosions.
• The people of New York have spoken. The NESE Pipeline has already been roundly rejected in response to tens of thousands of public comments. Simultaneously, a huge social movement won the passage of legally binding climate goals in the Climate Leadership and Community Protection Act. National Grid needs to get the message. It’s time to stop funding methane gas. It’s time to fund the solutions.