Cayuga Repowering Proposal Submi ing Public Comments to the Department of Public Service

Public Comments about the Cayuga Repowering Proposal are due by August 16th. You can mail comments to: Hon. Jerey Cohen Acting Secretary of the Commission New York State Public Service Commission Empire State Plaza Agency Building 3 Albany, NY 12223-1350 You can email comments to: secretary@dps.ny.gov You can also submit 4000 character comments online: Go to h p://bit.ly/1alRwuA and click Post Comment in the upper right hand corner. The most eective comments are ones that are wri en by people who are aected by the decision (be sure to say how you are) and that include well-informed arguments. Please focus your arguments on the question facing the PSC, repowering with fracked gas or permanently retiring the facility and making cost eective transmission upgrades. Here are some arguments in opposition to the repowering of the plant with fracked gas:
Increased Demand for Dirty Fracked Gas and More Fracking Infrastructure in New York State The economic viability of the natural gas repowered Cayuga Plant relies on the assumption that the price of gas will remain inexpensive and consistent. The only way for prices to remain stable is for the industry to extensively exploit the Marcellus Shale region, which will increase the pressure to begin High Volume Horizontal Hydraulic Fracturing for gas in New York State. Not only does this increase the long-term use of gas, it also begins the building of a network of pipelines to transport this gas. This region's energy future should not be tied to fracking. This conversion of the plant would require an 18 mile pipeline to be built to connect to the Dominion pipeline in Freeville. Rights of way for the pipeline will be taken from private

landowners by the use of eminent domain, which allows the government to expropriate private property for public use. The Dominion pipeline would disrupt the farmland it runs through, negatively impacting landowners and disrupting sensitive ecological habitats. The pipeline would also justify other pipeline expansion projects regionally, further industrializing this region. Methane is a Potent Greenhouse Gas, Not a Bridge to Sustainability A change from burning coal to the use of fracked gas will promote rapid climate change. Fracked methane gas is a potent greenhouse gas, many times more damaging than carbon dioxide, particularly when looking at a span of time over 20 years. According to a study done by Professors Robert Howarth and Tony Ingraea of Cornell University, when we take into account the full life cycle of extraction of methane gas via fracking, transmission of the gas, and then burning it, the greenhouse gas eect is close to that of burning coal and in fact may be much worse. Fracked gas has an intensely adverse eect on climate change, and should not be considered a solution. Who is impacted by repowering to fracked gas? Landowners- Rights of way for the pipeline will be taken from individual landowners by eminent domain. Pipelines are disruptive, running through and damaging farms and sensitive ecological habitat. NYSEG Ratepayers- The cost for the conversion of the plant, up to 370 million dollars, will be paid for by ratepayers, in a time when many are already struggling. Lower income folks will be disproportionately aected by these rate hikes. Workers- Analyzing a similar repowering proposal in Dunkirk, NY, National Grid calculated that the number of jobs lost due to the impact of the rate hikes would exceed the number of jobs created at that plant itself. Furthermore, Gas-red plants, like the one proposed, are unsafe and prone to deadly explosions. In 2010 in Connecticut, a similar plant exploded killing six people and injuring over 60. Frontline communities- Most of the gas will come from fracking in shaleelds across the country. This means that people living near fracking pads will face serious public health risks, groundwater contamination, the eects of industrialization and the destruction of agricultural ways of life. Increasing demand for gas also increases the likelihood of fracking in New York.

Indigenous people- The proposed repowering constitutes a violation of Native treaties including the 400-year old Two Row Wampum Treaty and ignores the rights of indigenous communities who have been living on this land for thousands of years. Economically Unsustainable The Cayuga Power Plant is currently insolvent, due to the relatively high cost of coal . This means that ratepayers are already paying 30 million additional dollars a year to keep the plant open, even though the plant is only needed to produce energy during peak demand. However, rate payer will be expected to pay up to 370 million dollars to convert the plant to run on gas. The alternative to repowering, upgrading transmission lines would be far more cost-eective meaning that NYSEG ratepayers, already struggling in a weak economy, would have to pay less on their energy bills. Ratepayers should not have to subsidize corporate prots and should only be asked to pay for eective long term solutions. Furthermore, even the economic viability of the converted plant is in question. In NYSEGs review of the repowering proposal, they pointed out that the price of gas is likely to uctuate more than estimated in the Cayuga Power Plants repowering proposal. With Obama pushing America to become a net exporter of fossil fuels and the price of gas becoming tied to the global market, the plant would again become insolvent as the price of gas skyrockets. Environmentally Sustainable Alternatives Need to be Explored Numerous credible alternatives to fossil-fuels have not been considered in this repowering proposal, an oversight which creates a false choice between accepting the fracked gas conversion or having to forgo any plants. NYSEG and the Sierra Clubs alternative proposal to upgrade transmission lines, rather than repower the plant, is a more eective immediate solution. According to the analysis conducted by the Sierra Club, NYS currently has more than enough electricity to meet its needs and simply has a problem with the transmission of adequate electricity to the areas customers. Transmission updates would therefore utilize existing resources to meet the areas needs, oering a more economically ecient alternative that avoids commitment to fracked gas and negates the need for a new major pipeline to provided the gas. A just transition for the town of Lansing could be provided by paying the Payment in Lieu of Taxes to the Lansing Central School District using funds such as the Regional Greenhouse Gas

Initiative (RGGI). RGGI funds have been used in Massachuse s in a similar manner when coalred plants have been retired. Transmission updates should be embraced as a solution to the immediate issue, but should be accompanied by a project to transition Tompkins County to long-term environmental and economic sustainability. The possible closing of the Cayuga Plant provides an exceptional opportunity to introduce renewables into our area. The New York State Energy Highway Plan has 5.7 billion dollars scheduled for use in the development of clean renewable energy resources. According to a recent study by Stanford Professor Jacobson, Cornell Professors Howarth and Ingraea, economist Jane e Barth and others, it is possible to move NYS totally to clean renewable energy resources by 2050 if we start now, and by 2030 we could be at 85% of this goal. We should use the plans for the Cayuga Plant and the opportunity the NYS Energy Highway Plan to get us started in that direction. Considering the large costs involved if the Cayuga Plant is repowered to use natural gas, there will be li le or no incentive to close it or convert it to renewable energy a er repowering to natural gas is completed. This disrupts the myth that the repowering by natural gas may be considered a bridge to sustainability. Options for the Cayuga Plant like wind, solar (with feed in taris), and energy eciency, rather, would create a shi towards environmental sustainability, and create long term, safe, local jobs and not damage the tax base. We can no longer delay action to move towards a sustainable future; now is the time to embrace renewable energy.