Dear Governor Cuomo, Public Service Commissioners and Energy Director Kauffman:

I am writing concerning the proposed "repowering" of the Cayuga Power Plant to burn coal plus gas vs upgrading the transmission lines in Auburn to meet that region's reliability needs.

 

I favor upgrading the transmission lines for the following reasons:

 

 

Do Everything Possible to Prevent Global Warming

We are headed toward a global apocalypse of our own making.  Every day the science on global warming is more dire and we have precious little time to change course before irreversible cycles set in that will render this planet’s fragile ecosystem incompatible with life.

 

We simply cannot continue on a business as usual path at this time of climate crisis.  We’ve got to stop using fossil fuels and switch to renewable energy as soon as possible.  It is for this reason that I urge you to reject the Cayuga repowering proposal and instead support transmission upgrades.

 

I commend the work you are doing to make New York a leader in the renewable energy revolution.  Keeping a greenhouse gas producing coal plant operating and adding another fossil fuel to the mix is a step in the wrong direction.   Please keep us moving forward toward energy efficiency and renewable energy power sources before it is too late.

Don't Build a Market for Frack Gas

Governor Cuomo was on the right track when he announced in December 2014 that he would ban fracking in New York State.   The process of high-volume hydraulic fracturing threatens the air, water, soil, landscapes, health, social and economic well-being of rural communities.  What's more, methane is 80 times more potent than carbon dioxide in increasing the greenhouse gas effect over the critical next 20 years, and significant leakage of the gas is inevitable both during and after the hydrofracking process.

 

It is unconscionable that the State is now contemplating converting the Cayuga Power Plant to burn natural gas from fracked communities outside of New York State.  Fracking is not okay in New York's backyard and it is not ok in other areas either.  Natural gas is not a bridge to the future, it is a bridge to climate and community disaster.  

 

Please invest in upgrading the grid, energy efficiency and renewable energy.  This is the direction we should be headed.

No More Coal.  Period.

As the entire nation moves away from coal-fired power plants – it is shocking to hear that New York's Public Service Commission has already required NYSEG customers to pay millions of dollars to keep the Cayuga coal plant open and is now considering requiring NYSEG customers to pay $145 million more to convert the plant to burn gas while retaining the ability to burn coal indefinitely. 

 

Allowing Cayuga Power Plant to continue to burn coal endangers people's health and the environment.  Toxic emissions from burning coal contain heavy metals including arsenic, mercury and lead, which poisons our drinking water and streams.  And those who live within 12 miles of coal burning facilities  - often the most vulnerable members of our society, including children, the elderly, and low-income families - have higher rates of asthma, lung cancer, other respiratory illnesses and heart disease.

 

Instead of putting more money into an outdated, uneconomical, and dirty power plant – the PSC must reject the bailout of the Cayuga Power Plant and support the cost-effective transmission upgrades.

Transmission Upgrades are the Definitive Fix

NYSEG customers may be forced to pay $145 million over the next ten years so Cayuga can convert to burning gas along with coal in order to suppliment the electric supply to Auburn during times of peak demand.  Alternatively NYSEG could expand the main transmission lines that come into Auburn from the east, at a cost of $55 million.

 

Astonishingly, investment in Cayuga comes with no guarantees.  Cayuga does not guarantee that the plant will continue to operate beyond the 10 year bailout.  Indeed, if it becomes uneconomic during the 10 year period, or has another fire or other problem, NYSEG customers could be forced to pay an even higher subsidy to keep the plant operational, or the plant could simply shut down.  At the end of the 10 year subsidy the plant will almost certainly be uneconomic to operate and will close. 

 

Whenever the plant closes - whether during the ten year bailout or afterwards - NYSEG customers will then need to pay to upgrade the transmission lines in Auburn.  That's because upgrading the transmission lines in Auburn is the definitive fix.  Please don't waste our hard earned money bailing out Cayuga when there are less costly and more permanent options. 

 

Cayuga is Old, Inefficient and May Not Be Profitable

Compared to other power plants in our region, the Cayuga Power Plant is highly inefficient, and it will continue to be even if it is repowered.  The other power plants use a newer, energy efficient technology known as combined-cycle to generate electricty, compared to Cayuga's out-dated, simple-cycle method. 

 

In combined-cycle, the plant is able to capture the heat energy from fuel combustion and also the heat from the exhaust - and convert both to electricity.  In contrast, in simple cycle plants, the exhaust heat is not captured. 

 

Thus combined-cycle plants are 30-50 times more energy efficient than simple-cycle plants.  This energy efficiency translates into more power being generated for a given unit of fuel, so production costs of newer plants are lower.  Their emission costs are lower too, as they produce less C02 for a given unit of power produced. 

 

All of which raises the question whether Cayuga will be able to compete with these newer more efficient plants if it is repowered, or if it will once again become unprofitable to operate. 

 

It makes much more sense to improve the energy efficiency of the grid by upgrading the Auburn transmission lines, rather than forcing NYSEG customers to pay $145 million for an old, inefficient power plant that may not be profitable. 

It's Not Economic Development, It's Corporate Welfare

Since January 2013, NYSEG customers have been paying nearly $4 million per month to keep the bankrupt Cayuga Power Plant operating, and we are being forced to do so until at least June 2017, when a remedy to the reliability problem in Auburn is expected to be completed.  In total, NYSEG customers will pay over $200 million dollars to Cayuga's owners before the reliability problem is resolved.

 

Now, Cayuga wants us to pay another $145 million to convert their power plant to burn gas in addition to coal.   They claim the plant will provide economic benefits to the community in the form of jobs and taxes.  Yet they offer no guarantee that the plant will continue to operate once the subsidy ends, and no guarantee that it will be profitable once it is repowered.  Indeed, the 60-year-old plant could experience malfunctions that would render it inoperable and NYSEG customers would end up footing the bill for the less costly transmission upgrades after first paying for a the Cayuga repowering.

 

Let's be honest - paying $200 million plus $145 million to prop up an old, inefficient power plant with no guarantees that it will continue to operate is not an economic development plan - it is corporate welfare.   Tompkins County and NYSEG customers deserve better.

Reform the Energy Vision in Tompkins County

I applaud the Governor's Reforming the Energy Vision (REV)  initiative that seeks to increase distributed power generation, demand response, microgrids and energy efficiency, with stated goals of reducing greenhouse gas emissions and the costs of electricity. 

 

The Public Service Comission notes that one of the major expenses of our current electric system is for maintaining idle power plants that are only utilized for a few hundred hours of peak demand time per year.  The expense and inefficiency of this arrangement has been tolerated because it is balanced against the need for reliability.  But now, technological developments have made alternative methods of managing and satisfying demand more feasible and less costly.  

 

We should be moving forward with these new methods for meeting peak demand rather than allowing a 10-year bailout for the Cayuga plant, which undermines REV’s stated goals and would lock Tompkins County into a decade more of detrimental climate pollution.  Instead, please upgrade the transmission lines in Auburn and let's  continue on a path forward toward reforming the energy vision in New York State.

Invest in Infrastructure of the Future, Not the Past

The Pubic Service Commission will soon decide whether to require NYSEG customers to pay $145 million over the next 10 years to subsidize the continued operation of a coal plant that will be retrofitted to burn natural gas, or instead to require NYSEG customers to pay $55 million to upgrade the transmission lines which will make the electric system more efficient and reliable for years to come.   In addition to retrofitting the plant to burn gas, a new 14-mile high-pressure gas pipeline will need to be installed from Dryden to Lansing in order to deliver the fuel to the plant. 

 

In either instance, this is a lot of money to spend.  But at least upgrading the transmission lines will have lasting value - making the grid more reliable and energy efficient.  In contrast, over the next 10 to 20 years we need to drastically reduce our reliance on fossil fuels, which means that the investments in the power plant conversion and pipeline will be short-lived and we will be left with stranded assets.

 

Please do not spend my hard earned money investing in fossil fuel infrastructure that will soon be obsolete.    Please spend my money wisely, investing in the infrastructure that will still be needed in the future: efficient, reliable transmission lines.

Support the Community and the Workers

I am in favor of upgrading the Auburn transmission lines and not converting the Cayuga Power Plant to burn gas along with coal.  Cayuga's proposal is not in the interests of either the ratepayer or the environment and should be rejected.

 

However, I am aware of the economic impact to the community if the power plant closes, and feel this must be addressed too.  The power plant employs 60 workers and pays nearly $2 million per year in property taxes to support the Lansing School District, the Town of Lansing and Tompkins County.  

 

I feel strongly that the State must not make energy decisions based on the impact closing the plant will have on the community in which it resides.  If the State did that, our energy policy would never advance.  We must move forward to a fossil fuel free future as soon as possible. 

 

But the State must also provide support to the community so that it can transition to a new economic base. Therefore I ask that Governor Cuomo provide support to mitigate the tax impacts from plant closure. Please also provide job training support for the workers.  Last, please provide economic development support to help develop new businesses in the Town of Lansing.

Protect the Ratepayers

The owners of Cayuga are currently receiving a bailout costing New York electric customers nearly $4 million a month until 2017 to keep them operating to meet reliability concerns in Auburn.  Now Cayuga’s owners, Upstate New York Power Producers, are seeking another bailout that will cost NYSEG customers over $145 million to convert the plant to burn natural gas.  What's more - there is no guarantee the plant will  be profitable or continue operating after it receives the bailout.

On the other hand, Auburn transmission upgrades will provide a definitive fix to the reliabilty concerns at about 1/3 of the cost.  

 

New Yorkers already pay the highest electric rates in the continental U.S.  The Public Service Comission has a responsibility to keep our rates as low as possible while still maintaining adequate service.  The cost of Cayuga's proposed bailout will be borne disproportionately by upstate businesses and people with fixed and low incomes.   The choice is clear - upgrade the Auburn transmission lines.