The Northeast Supply Enhancement (NESE) pipeline is a proposed pipeline to bring natural gas to New York City and Long Island. I sent Comments submitted 27 March 2020 in a New York Department of Public Service proceeding related to denial of service requests by National Grid in New York City and Long Island which is associated with this project. This post describes what is going on, the proposal to resolve the issue and my comments on the proceeding. Be forewarned there is a lot of material to cover so this is a long one.
Purpose
The request for comments is in regard to a requirement to come up with alternatives to provide additional natural gas supply to National Grid’s service territory on Long Island. In this section I explain what happened to the original plan to fix the problem and events leading up to the current discussion. On May 15, 2019 the New York State Department of Environmental Conservation (NYSDEC) denied a water-quality permit for the NESE natural gas pipeline that would bring more natural gas to New York City and Long Island. On May 24, 2019 National Grid imposed a moratorium on new natural gas connections In New York City and Long Island because they could not guarantee enough supply for additional customers based in part because the pipeline was blocked. In late November 2019 National Grid relented and started doing hookups for new customers following threats from Governor Cuomo to pull their license to operate. The fact remains that the there is still a problem so National Grid has developed a collaboration for a “safe and reliable energy future”. I submitted my comments in response to the public outreach program related to this effort. Once that effort is complete all the feedback will be collected and reviewed, and the National Grid will issue a supplemental report that summarizes and includes public and customer input. This is supposed to “enable an agreed long-term solution(s) with New York State by June 2020” so that the solution(s) can be in place and in operation by the winter of 2021/2022.
Water Quality Permit Denial
In order to ensure adequate supplies Transcontinental Gas Pipe Line Company (Transco) proposed the Northeast Supply Enhancement Project (NESE). The permit application project description states:
The NESE Project is a 26-inch diameter pipeline proposed by Transcontinental Gas Pipe Line Company LLC (Transco) that would transport natural gas from Pennsylvania through New Jersey, traveling underwater in the Raritan Bay and Lower New York Bay to approximately three miles offshore of the Rockaway Peninsula in Queens Borough. Approximately 23.5 miles of underwater pipeline will be installed, of which approximately 17.4 miles would be in New York State waters.
The NESE Project would connect to the existing Rockaway Delivery Lateral in Queens and would provide 400,000 dekatherms per day of incremental capacity to National Grid to serve customers in Brooklyn, Queens, and Long Island. According to Transco, the project is intended to support reliability as well as help displace the use of oil.
The NESE Project would be installed a minimum of 4 feet below the sea floor through a combination of jet trenching, clamshell dredging and horizontal directional drilling (HDD). Construction would be phased to avoid potential impacts to marine species. If permits are ultimately issued, compensatory mitigation would be required to offset unavoidable impacts to benthic resources, including shellfish.
On May 15, 2019, the NYSDEC denied the application for the required Clean Water Act Section 401 Water Quality Certification based on their review of the permit and over 14,000 public comments received on behalf of 45,000 individuals. The full decision (PDF) is outlined in a letter by Daniel Whitehead, Director, Division of Environmental Permits, NYSDEC. I summarize the rationale below.
Because this is an interstate pipeline project the Federal Energy Regulatory Commission (FERC) has to approve the application to build the pipeline. On March 27, 2017, Transco submitted to FERC an application for a Certificate of Public Convenience and Necessity for construction and operation of the Project. FERC issued a Draft Environmental Impact Statement (DEIS) on March 23, 2018. The NYSDEC submitted comments to FERC regarding the DEIS on May 14, 2018 and FERC issued a Final Environmental Impact Statement (FEIS) for the Project on January 25, 2019. The FEIS outlined some of the numerous environmental impacts FERC anticipated from the construction and operation of the Project. On May 3, 2019, FERC issued Transco a Certificate for the Project subject to certain environmental conditions recommended in the FEIS. According to FERC, these conditions would mitigate many of the environmental impacts associated with the Project.
Even though FERC approved the project Transco still had to get a Water Quality Certificate from New York State. After the usual iterations between the applicant and the NYSDEC, the application for the Certificate was deemed complete on January 30, 2019. When the application went out for public comment well over 90 percent of the 14,000 public comments opposed the Department’s issuing a Certificate. On the basis of their review of the application and public comments, NYSDEC determined that there would be significant water quality impacts. This includes “significant water quality impacts from the resuspension of sediments and other contaminants, including mercury and copper. In addition, as proposed, the Project would cause impacts to habitats due to the disturbance of shellfish beds and other benthic resources.”
All environmental impacts involve tradeoffs. If resuspension of sediments were the deciding criterion and prohibited in every instance then no project that disturbed an underwater surface could proceed – no bridges, no docks, nothing. For that matter fisherman’s dredges that are towed along the bottom could be prohibited. In a rational world, the fact that all those activities and the construction of a pipeline are short-term would be considered and if the overall long-term benefits to society out-weigh the transient impacts then the permit would be approved. This instance is complicated by the fact that the sediments are contaminated, so mercury and copper limits could be exceeded. Again, if this is the criterion, then no work that disturbs sediments in New York harbor should be permitted. Another unavoidable impact is habitat disturbance and the same trade-offs apply. However, the State could have required Transco to rehabilitate the disturbed shellfish beds after the pipeline was installed.
This is an example of hypocritical decision making by the Cuomo Administration. NYSDEC rejected the National Fuel Gas Empire Pipeline application for a new 97-mile pipeline because it would have caused permanent impacts to 2.335 acres of wetlands within the 73.377 wetland acres impacted. The poster child for Cuomo hypocrisy is the rejection of the Finger Lakes LPG application for an underground storage facility because of “significant adverse impacts on community character” when the only visible infrastructure was a small pond and a building. On the other hand agencies have approved the Cuomo-correct applications for off-shore wind farms which will permanently disturb much more of the seafloor than the NESE pipeline would have temporarily disturbed, approved projects that permanently disturbed wetlands but allowed the developer to create compensating wetlands, and approved wind and solar applications that have significant impacts on community character. There is absolutely no question in my mind that the professional staff at NYSDEC and the other NYS regulatory agencies, if left to make permitting decisions based on their experience and the facts of the case, would have approved all of the rejected applications. The reason there were rejected was the Cuomo Administration.
National Grid Moratorium
National Grid’s problem is that they have determined that there is not enough current gas supply to serve future customers. In their report they explained that 85% of the gas used on the coldest days is used for heating. If they don’t have enough gas available then service to existing customers will be jeopardized and that means heating supplies will be at risk. In my comments I provided references that conclusively show that cold weather is more impactful on health than hot weather and I have also shown that claims that hot weather is worse are based on a reporting artifact related to different lag times for hot and cold effects. Therefore, National Grid has the moral responsibility to ensure heating supplies are available and the State should support those efforts.
Gas supply is regulated by the Public Service Commission (PSC) so the projection methodology is comprehensive and well-documented When a utility company calculates how much supply they have, how much they are using and how much they will need in the future to argue that they need more supply infrastructure, the first thing PSC staff does is generate their own analysis using the same methodology. The two sides compare projections to determine if there are differences and reconcile the numbers. My point is that the assumptions used in these calculations have been developed over the years to ensure adequate and reliable gas supply and they should not get changed at the whim of anyone.
Faced with their analyses that show they don’t have enough gas for future additions and with the rejection of the solution that they had planned to use to resolve the problem National Grid announced that they had to put a moratorium on new supply hookups.
Cuomo’s Response to the Moratorium
In the fantasy world of Cuomo’s New York, numbers, facts, and precedence don’t matter. It is all about Andy. Once people could not get the preferred alternative of a natural gas hookup they squawked and the politician saw an opportunity to cater to voters. His response was to have the Public Service Commission order National Grid to provide natural gas hookups. According to the New York Post “The Public Service Commission said it has the authority based on a section in Public Service Law that says if a gas company is unable to meet the needs of reliable service to customers, the state has the power to step in”. Following established State practice National Grid calculated how many customers they could handle and cut off any additional customers when the infrastructure proposed to resolve the problem was rejected by the State. Obviously National Grid was unable to meet the needs of customers solely because the State would not let them,
Furthermore, Cuomo huffed and puffed a threat to revoke the operating license for National Grid if they did not comply. Now here is where the precedence issue arises. The Department of Public Service (DPS) and Public Service Commission are supposed to be independent. In this instance an independent agency could have said “Sorry Governor but your politically driven appeasement of your voting base meant that there may not be enough gas supply available and in order to protect the citizens the prudent choice is to put a moratorium in place.” The problem is that the DPS no longer independently serves the public interest. In the summer of 2019 a group of retired Department of Public Service employees submitted a letter that stated “Until the current administration, Governors have generally respected the plain language of the Public Service Law (PSL), which … safeguards the mission of the DPS to serve not political interests but the public interest.” The letter signed by fifteen retired department workers states: “Governor Andrew Cuomo, however, has not done so.”
Like most bully threats there are questions whether Cuomo could have actually revoked National Grid charter to operate. Nonetheless it was a thinly veiled threat to step in line or he would make doing business miserable. National Grid is a business and in order to succeed financially they depend on a rate-making process that is entirely co-opted by the Cuomo Administration. If National Grid steps out of line there is no question that his Administration will hurt them as often and as hard as possible.
National Grid Interim Solution
Not surprisingly National Grid caved and agreed to lift the moratorium for two years. According to a Utility Dive report:
National Grid has identified new solutions to supply consumer gas needs in downstate New York since announcing the moratorium, company spokesperson Domenick Graziani told Utility Dive in an email. These include a “previously unavailable source of short-term peaking supplies,” which he declined to provide further details on.
The utility also anticipates reductions in demand due to energy efficiency and demand response programs, a new compression project that will provide additional long-term capacity to portions of Long Island and a greater-than-expected number of customers interested in shifting to “non-firm” service — that is, customers who switch to oil or other alternative fuels when asked to by National Grid. These customers are charged differently from residential and other “firm” customers and can be penalized if they don’t make the switch, according to Graziani.
As noted, before, environmental development issues involve tradeoffs and that is also true for energy development. In this instance the “previously unavailable source of short-term peaking supplies” turned out to be trucked compressed natural gas. This option requires a facility where the gas is compressed outside of Long Island and loaded into trucks that transport it to a vaporization facility on Long Island where it can be vaporized and added into a pipeline for delivery. Natural gas can be transported from the production well to the user entirely by underground pipelines. While there are safety and environmental issues related to that relatively simple approach there is no question that the CNG truck option through New York City is much riskier and that environmental impacts will be greater when additional handling components are added to the transport from well to user. Elsewhere this “virtual pipeline” is widely condemned so it is not surprising that the National Grid spokesman declined to provide further details.
This is another instance of Cuomo administration hypocrisy: on one hand basking in the limelight as a leader against climate change by prohibiting new fossil fuel infrastructure but on the other hand needlessly risking safety and increasing environmental impacts with a solution only intended for use as a stop gap in emergencies. Mark my word if there is CNG truck accident it will be anybody’s fault but Cuomo’s.
National Grid Collaboration
At this time National Grid is conducting an outreach program as described below:
For National Grid, serving our 1.9 million natural gas customers across Brooklyn, Queens, Staten Island, Nassau, and Suffolk is both a privilege and a responsibility. New York has seen dynamic economic growth in the Downstate region, expanding residential and non-residential building space, and thousands of oil-to-gas conversions over the last 10 years. These factors have resulted in a substantial increase in the demand for natural gas, placing stress on our existing gas network and threatening National Grid’s ability to meet our customers’ needs when demand is at its peak. This leaves little room for error in the face of unplanned supply interruptions or other contingencies.
As part of the settlement agreement with New York State that lifted the moratorium on new gas connections imposed in May 2019, we are taking numerous measures to ensure we have sufficient supply for the winters of 2019/2020 and 2020/2021, including increasing reliance on compressed natural gas (“CNG”) trucking when needed to meet peak demand.
Beyond the next two winters, however, continued growth in demand for natural gas creates a challenge that must be addressed. There are multiple potential solutions, each with its own considerations regarding safety, reliability, environmental and community impact, and cost. National Grid has prepared and provided to New York State an extensive Long-Term Capacity Report to facilitate constructive dialog in the quest to answer the challenges presented by increasing demand. The purpose of this Summary Report is to distill the content of that full report for the general public so that all may understand the issues involved and the potential solutions to be considered.
We wish this to be a collaborative process and encourage feedback, either through the public meetings hosted by National Grid in March 2020 or by sharing your thoughts via our online survey at www.ngrid.com/longtermsolutions. This site also provides access to the full report and a link through which you can share feedback directly with the New York State Department of Public Service.
In other words, National Grid is desperately trying to appease the Governor who wants to play to the no fossil fuel infrastructure maniacs he actively courts. To do that they have come up with this stakeholder process that lays out the problem and offers a number of alternative approaches to the problem. All the while trying not to favor any of them.
My Submittal
National Grid has developed a slick website that provides information on the long-term solution options. Also included are links to the reports, schedule of events, ways to submit comments, and transcripts from their meetings. I will describe the summary report and reproduce some of the comments I submitted in italics.
In the first section of the summary National Grid describes the problem. In order to define how much natural gas will be used they use the “Design Day” concept. This is the plan for peak demand conditions as the level of gas delivery needed to serve all of our customers during an extreme cold weather event. In the Downstate NY region Design Day is defined as a 24-hour period that averages 0° Fahrenheit in Central Park. They note that approximately 85% of this Design Day capacity is used to heat homes and businesses—keeping people warm on the coldest of days.
I frankly could only stand listening to the comments made during the public meeting for a brief period but in that time two people complained about the use of 0° Fahrenheit as the design day because temperatures have been warming. I am frustrated that they spout off numbers without any consideration that they have no responsibility in the event that they are wrong. Moreover, I am sure that the choice of the design day temperature is proscribed by some PSC order somewhere to prevent gaming the system so it is unlikely that changing the number could be considered. Nonetheless, I accessed Central Park data to see whether that value is representative to prepare the following comment:
I am a meteorologist so I checked the representativeness of the 0° Fahrenheit in Central Park criterion. I used the Northeast Regional Climate Center CLIMOD 2 data portal to download Central Park daily minimum, maximum and average temperature data from 1869 to the present. Over that period the lowest daily average temperature was -5.5° Fahrenheit and there were six other days with daily average temperatures less than or equal to the 0° Fahrenheit design day criteria. Note also that on December 30 and 31, 1917 there were two days with average temperatures below 0° Fahrenheit in the midst of a seven-day period with daily average temperatures less than 10° Fahrenheit.
I also evaluated hourly meteorological data for two NYS Mesonet stations (Rush and York sites from December 29, 2017 to January 8, 2018. In that period the temperature did not get above freezing and on January 6, 2018 the average temperature was 0.8° Fahrenheit. Based on my meteorology background and despite the fact that the most recent date with an average zero degree design day temperature in Central Park was 15 February 1943, I believe the weather conditions that caused a 0.8° Fahrenheit average day near Rochester in 2018 support the continued use of the 0° Fahrenheit in Central Park criterion. Because 85% of the Design Day capacity is used for heating this design day criterion may not be stringent enough and certainly should not be adjusted upwards.
National Grid discussed historical demand growth and made two projections, a high-demand and a low-demand scenario, to bound their analysis. In the high demand scenario, they assume that 80% of the State energy efficiency targets are achieved and in the low demand scenario they assume that 100% of the targets are achieved. Based on the projections and factoring in low-carbon solutions they predict that they will need to close a gap of 400 MDth/day between customer demand and available natural gas supply with the existing system.
In contrast to National Grid’s optimistic projection that they will reduce demand growth by over 50% I disagree. In the first place, New York has already had extensive energy efficiency efforts in place during the time that demand growth increased 2.4%. As a result, the easiest and most effective, aka low hanging fruit, energy efficiency projects have already been implemented. Any future reductions will not be as cheap or effective. Another problem is that natural gas works well for heating and cooking so it is the preferred alternative. The “no new fossil-fuel infrastructure” argument is fine in theory but when faced with having to choose a poorer alternative I believe there will be plenty of pushback from the majority of the population that wants the advantages of natural gas and is not as motivated as the environmental advocacy folks so vocal in this proceeding.
This is particularly true with regards to home heating electrification because the preferred retrofit alternative is air source heat pumps. My personal experience with this technology has been bad and I think that is a major problem for those who want to electrify heating. The word on the street is more often negative than positive. In my case I did research to try to understand the problem. In my 9/16/2019 filed comments on Resource Adequacy Matters, Case 19-E-0530, I included an analysis in an appendix entitled Air Source Heat Pumps that demonstrated the fundamental flaw with this technology. In short, when the temperature drops below 20° Fahrenheit there simply is not enough energy to be transferred and converted to heat for the technology to work. In the event of a seven-day cold snap like the one that occurred around New Year’s Day 1918 anyone without supplemental heat would freeze and the increased electrical load needed to provide supplemental electric resistance heating could lead to unprecedented peak loads. Claims that improved air source heat pumps will solve this problem are unwarranted absent repealing the laws of physics.
As a result, I do not think that the low demand case in which 80% of the State energy efficiency targets are achieved is likely. More realistically the low demand will be 50% of the targets and the high demand 80%. I am confident that 100% of the State energy efficiency targets will not be met.
Another aspect of the National Grid demand reduction plan is to use three low-carbon solutions: renewable natural gas, hydrogen blending and power-to-gas, and geothermal heat pumps. National Grid claims that “with proper funding and support, we anticipate that these programs can cover 15–35 MDth of the Downstate NY gas supply gap”.
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- Renewable natural gas (RNG) facilities use biomass—such as landfills, wastewater treatment, food waste, and livestock manure— as feedstock for producing gas. National Grid currently has two RNG sites in their Downstate NY region: one on Staten Island and another at Newtown Creek expected to come online in the winter of 2020. They believe there is even more opportunity to expand RNG in their Downstate NY region.
- Natural gas supplies can be augmented by blending in hydrogen gas produced by splitting water into hydrogen gas and oxygen gas through the process of electrolysis. Hydrogen blends, in the form of town gas, were used in heating for decades, both in the US and other countries. National Grid has proposed a two-year study to assess optimal parameters for incorporating hydrogen in the Downstate NY region.
- By transferring heat to and from the ground, geothermal heat pumps offer an attractive, low-carbon alternative for providing central heating and cooling. Based on the success of a demonstration project that connected 10 homes with shared-loop ground-source heat pump (GSHP) systems, National Grid is seeking to expand this program to 900 homes over the coming four years.
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As shown below I don’t think these projects have much, if any value. At the Trust Yet Verify blog, the author notes that in Flanders, they have the expression “calculating oneself rich” which means presenting one’s case in a too optimistic way that doesn’t accord with reality. Had I been aware of that expression when I wrote the comments, I would have used it because it describes these projects well.
Renewable natural gas is produced from anerobic digesters. The New York State Energy and Research Development Authority (NYSERDA) has an integrated data system that provides operational data on DERs installed in New York including anerobic digesters. At the current time there are 38 facilities with a rated electrical output of 22,263 kW. The majority (29) of these digesters are located on dairy farms. Eight are at waste water treatment plants and one is located at the Saranac brewery. Only three of these have output greater than 3 MW and the majority are rated between 100 and 500 kW. It is telling that NYSERDA rates these by electrical output because that indicates that the methane is primarily used to generate electricity. The National Grid report states that the Newtown Creek WWTP will be capable of producing 1.0 MDth/day and that they are “connected to a 1.6 MDth/day plant in Staten Island”. Presumably during peak natural gas demand periods, the plan could be to divert the methane to the gas system rather than using it for generating electricity. I believe that this option has limited potential simply because there are not many possible sites where it could be deployed.
National Grid has proposed a two-year study to assess optimal parameters for incorporating hydrogen in the Downstate NY region. In other words, this is more of a concept than a proven technology in today’s energy landscape. Cynic that I am I consider this more wishful thinking than an actual plan.
Ground source heat pumps work but the implementation logistics of trying to install meaningful amounts even, if the geology was favorable, in the service territory for this proceeding precludes this as a viable contributor to meaningful load reductions.
The meat of the report is the description of ten distinct options for closing the gap of up to 400 MDth/day between natural gas demand and supply over the next 15 years. National Grid is careful to state that they do not propose a “best” or “most desirable” solution and pragmatically observe that the ultimate approach ultimately will likely be a portfolio including two or more of these options. As noted earlier they have the responsibility to provide natural gas and the politicians who demand solutions that are driven by an agenda will disavow any culpability if they don’t work.
National Grid proposes ten projects in three categories. They propose three large-scale infrastructure projects: an offshore liquified natural gas (LNG) deep water port, an LNG import terminal, and the Northeast Supply Enhancement pipeline project. There are four distributed infrastructure projects: a peak LNG facility, LNG barges, the Clove Lakes Transmission Project, and the Iroquois enhancement compression project. There are three no-infrastructure projects: incremental energy efficiency, demand response, and electrification.
The summary report concludes with an assessment of the relative attractiveness of the proposed options with respect to each of the evaluation criteria to “help our customers and the general public evaluate the options”. I reviewed and commented on the scoring but will not include all my comments here. In brief, I think that by necessity National Grid scored the NESE pipeline lower than they should have to be “Cuomo correct”. For example, they gave all the large infrastructure projects the same safety score. I disagree because in most things related to safety simpler is better. Both LNG alternatives are significantly more complicated because they involve storage and regasification components. Moreover, they both require marine transport which compared to a pipeline has to be less safe. I suggested that the scores for those projects be dropped relative to the pipeline.
I did include a comment on the environmental scoring because I have a lot of experience with environmental impact analyses and I disagree with the environmental scoring. Frankly the evaluation criteria in the report in Table 19 don’t help much. Greenhouse gas (GHG) emissions is one criterion used. I don’t see how the compression, regasification, and transportation components of the LNG options would not mean higher GHG emissions. All the other GHG emissions intensity values are the same for all three options. As a long-time air quality meteorologist, I struggle to find air substantive air quality problems with natural gas use as compared to other dispatchable sources of energy but I believe that air pollution emissions from LNG ship transportation are larger than pipeline compressor stations. I can accept that the potential impact from construction is higher for pipelines but once in place the operation impacts are likely lower. I assume that environmental risk relates to the ecological impact. The fact is that there have to be pipelines from the well pads to the ports for the LNG options. Expanding pipeline capacity to bring the needed natural gas directly to the City is simpler, safer and less prone to problems. I cannot comment on the potential of any option to support New York’s decarbonization goals because there is no plan to implement those goals, only targets. The politicians that enacted legislation with the goals made a major mistake putting the cart (the aggressive targets) before the horse (figuring out what was feasible). In conclusion I would add another cell to the environment scoring bar to the pipeline option because it is significantly better than the other two.
Two of the distributed infrastructure projects, Clove Lakes Transmission Project and the Iroquois enhancement compression project, are simple upgrades that will provide more capacity. I see no reason why they should not be included.
The no-infrastructure projects all qualify as “Cuomo correct” virtue signals. Because I don’t believe that the existing energy efficiency targets will be met, I reject out of hand the idea that even more substantive energy efficiency could be implemented. Demand response is a favored component of “smart grid” advocates for shaving summer peak demand. However, that is not a solution here because the expectation is that the load peak will shift to the winter. I believe that there are significant differences between cooling peak loads and heating peak loads. Most importantly, there is a hot period diurnal cycle that means that shifting between uses (A/C is not as large a component of total load as heating is to the total load) and times (when the sun is down there is no direct solar heating and cooling load needs drop significantly) is possible. The question boils down to this: when 85% of your load is heating and the heating load does not vary much how can you shift the load? I for one would not accept a thermostat that someone else controls for heating my home. I do not think I would be an exception.
The third no infrastructure project was heating electrification using cold-climate, electric heat pumps. I think that widespread implementation of cold-climate heat pumps will be a mistake as I noted in my resource adequacy comments. Bottom line is when you it is really cold and you really need heat they don’t work simply because there isn’t enough energy available. In addition, you are just shifting the problem onto the electric side. Given that electric transmission is more susceptible to interruption than pipelines I think electrification is a less resilient option.
The only positive that can be said about these no-infrastructure projects is that they are consistent with the Climate Leadership and Community Protection Act (CLCPA) expected infrastructure. Unfortunately, we are guessing at what the state plans to do because they set targets without figuring out if they could be met much less how they would be met. Moreover, I don’t think that the implementation timing for these kinds of projects will be consistent with timing for when the gap between demand and supply needs to be reduced.
National Grid points out that “Creating a comprehensive solution requires looking at how different options can work together to solve the gap between demand and supply”. Then they listed three possible approaches. I was disappointed that they did not include the NESE pipeline large-scale infrastructure and the two distributed infrastructure pipeline projects as an option. I commented:
It did not get much attention in the documentation but the solution to the fact that current pipeline capacity cannot support today’s peak load demand is to truck compressed natural gas from somewhere on the other side of the supply constraint to somewhere on the inside of the supply constraint. In my evaluation of the difference between pipeline and LNG infrastructure options I argued that the added safety and environmental effects of marine transport relative to pipelines made pipelines a superior choice. However, the safety and environmental effects of trucks are greater than those of marine transport. All three solutions rely on incremental Energy Efficiency, Demand Response, and Electrification to reduce demand and remove the need for CNG trucking. As a result, I could never support any of these solutions simply because it is likely that the need for CNG trucking will remain longer.
The first combined option, build out Large-Scale Infrastructure, capable of almost fully meeting projected needs claims that if construction is not completed before 2021/22, incremental Energy Efficiency (EE), Demand Response (DR) and Electrification would be required to reduce demand and meet customer needs. CNG trucking would be discontinued once the infrastructure is completed. Any shortfall in meeting demand reduction targets would lead to restrictions on new customer connections until the infrastructure is completed. Incremental EE, DR and electrification won’t be implemented in this time frame – no way no how.
The second combined option, combine distributed infrastructure solutions with incremental No-Infrastructure solutions fails because all of them need to be implemented to meet projected gap so it will be necessary to combine one or two of these options with additional demand reductions achieved through EE, DR, and Electrification to fully meet needs. National Grid admits CNG trucking would remain in place unless demand reduction targets are exceeded, and any shortfall in meeting those targets would lead to restrictions on new customer connections. Given that I think there is no way the demand reductions will be met CNG trucking remains in use for longer.
The final combined option, fully rely on a portfolio of incremental no- Infrastructure solutions, will undoubtedly be the preferred alternative of the energy innumerate and, thus the king of innumeracy Governor Cuomo. Because it is unlikely that demand reduction targets will be exceeded, CNG trucking will remain in place, and any shortfall in meeting such demand reduction targets will lead to restrictions on new customer connections. Somehow, someway when this fails to meet the needs, Cuomo will be the first to blame National Grid.
Conclusion
National Grid states: “Our hope is that by helping our customers understand the possible approaches for addressing these concerns, they will provide feedback to help guide future decision making.” Let me translate that for anyone unversed on current New York State energy policy. National Grid is a business and in order to succeed financially they depend on a rate-making process that is entirely co-opted by the Cuomo Administration. This report and the extensive outreach program, is a necessary part of doing business but it is just window dressing. The ultimate decision will not be made to balance costs and risks against benefits to customers. Whatever the facts say about energy reliability, effects on health, safety risks and costs, the final plan will be a politically driven decision made at the highest level of the Administration based on whatever is determined to best garner support from Cuomo’s political base.
This is another instance of Cuomo administration hypocrisy: on one hand basking in the limelight as a leader against climate change by prohibiting new fossil fuel infrastructure but on the other hand needlessly risking safety and increasing environmental impacts with an interim solution only intended for use as a stop gap in emergencies. There are three pipeline alternatives that should be the clear choice as less risky, safer and minimal environmental impacts. The other long-term infrastructure alternative solutions include several options that would continue to use more complicated and thus more risky approaches. The obligatory no-fossil fuel infrastructure options could, in theory, provide enough energy needed to meet the design day criteria but two of the options (electrification and demand response) have never been implemented on the scale necessary and expecting to get even more energy efficiency reductions runs counter to observed results. The question is whether the Cuomo administration will risk safety and reliability by requiring the use of those risky approaches to cater to people who will pay no price for being wrong.
Of course, the underlying argument that forms the basis of this entire charade is that climate change is an existential threat. I believe that is a flawed argument. New York’s politicians constantly claim that their energy policies have scientific support and they typically lean on the popular conception of an overwhelming consensus that the observed warming is necessarily bad. In reality, most qualified scientists believe humans are causing some warming, but only a minority are very concerned about it. The catastrophic impacts touted as proof that something needs to be done invariably rely on a future emission projection scenario that is so unlikely that it is inappropriate to use for policy decisions. Finally, if the problem is global warming then it logically requires a global solution. The reality is that New York’s possible impact on global warming reduction is too small to measure and would have effects that could not conceivably alter any of the purported catastrophic impacts.
Pragmatic Environmentalist of New York 