Wigwam received this action alert from Scenic Hudson this morning:
ACTION ALERT: Public Comments Needed by Friday, Aug. 29!
The state Public Service Commission (PSC) has released a proposed outline for moving forward new transmission line projects. The proposal basically starts the whole process over—without addressing any concerns raised by the Hudson Valley Smart Energy Coalition (HVSEC) and its member organizations.
We have until Friday, Aug. 29, to tell the PSC there are big problems with this proposal!
In a nutshell, here’s what it contains: by Jan. 15 developers may submit their original plan, a modified plan or, with no obligation or incentive, an alternative that stays within existing rights-of-way. Assisted by the New York Independent Systems Operator (NYISO), PSC staff will rank each plan based on six criteria, including amount of increased transfer capability, cost to ratepayers, new rights-of-way needed and assessment of environmental compatibility, including visual impacts. The proposal gives no indication of how these criteria will be applied or weighted. The rankings, along with recommendations for which projects should proceed, will be submitted to the PSC by March 2, 2015. The public will have only three weeks to respond and comment on the recommendations.
Under this proposal, 90 percent of the cost of any projects will be passed to downstate customers (including those in Dutchess County) and 10 percent to upstate customers. Further, project developers will suffer only 20 percent of the risk of going over budget—with ratepayers picking up the remaining 80 percent of the tab.
Here are our main concerns:
- Need. The proposal leaves off the table the question of need. To date there has been no independent study taking into account trends in electricity usage, technological innovation, parallel generation and advances in demand side management. Instead, the process starts from an assumption of need.
- Context. There are currently a multitude of electricity-related projects and applications proceeding simultaneously in New York, each within its own “silo,” none being considered in the context of others. To avoid duplicative, inefficient or unnecessary development, a comprehensive state energy policy should take into account all of these initiatives.
- Uncertainty to property owners. Valley property owners will continue suffering economic harm from decreased property value, diminished farmland, stifled tourism and an uncertain real estate market. The PSC is offering reimbursement to developers for their costs in creating proposals, but offers nothing to businesses, landowners or communities taking an economic hit during this lengthy process.
- NYISO. Although the NYISO has the word “Independent” in its name, there are legitimate concerns about the transparency of its methods. Some feel NYISO’s makeup of previous electricity industry professionals inclines it to favor projects beneficial to the industry. Because this perception exists, NYISO should display maximum transparency regarding its evaluation process and methodology.
- Ranking. Although it’s encouraging to see right-of-way usage, visual impact and innovative technologies among the six criteria by which projects would be ranked, there is no mention of how the criteria would be weighted in the selection process. What might be most important to the PSC or NYISO could negatively impact the valley’s economic vitality.
- Cost allocation. Based on cost allocation proposed in the new document, ratepayers in the area to be economically hardest hit by a new transmission project—the Hudson Valley—also must pay the lion’s share of the costs of selected projects, as well as the vast majority of cost overruns and likely all the expenses of unsuccessful applicants. Having the public assume 80 percent of the financial burden of cost overruns incentivizes developers to come in over budget and discourages efforts on their part to cut costs.
Time is short—Friday is the deadline for commenting on this new proposal via the PSC’s website. Visit this link and click on “Post Comments” near the top of the page. You’ll be directed to a form where you can state your concerns.
Please don’t delay. Let the PSC know today that this proposal does not address the major concerns of valley residents.
Thanks for all that you do.