Letter to Federal Energy Regulatory Commission

April 23, 2020

Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC 20426

Re: Docket No. CP20-48-000 – Iroquois Enhancement by Compression Project

Dear Secretary Bose,

On behalf of New Yorkers for Affordable Energy (NYAE), a coalition of community, labor and business leaders from across the state who support efforts to expand access to natural gas for consumers and businesses, I write to you in support of the Iroquois Gas Transmission System’s (Iroquois) Enhancement by Compression Project (ExC).

In recent years, natural gas distribution companies in New York have worked to manage growing demand stemming from New York’s own policies designed to drive down usage of oil and coal. As customers comply with the mandated phase-out of No. 4 and No. 6 heating fuel oils, natural gas is the only cost effective option for new commercial and multifamily construction, as well as for modifications to existing structures. Despite the tremendous increase in demand, New York hasn’t added enough natural gas pipeline capacity – in fact it has blocked much-needed projects that would bring new supplies to the region. At the same time, New York has also refused to allow local distribution companies to place a moratorium on new hookups, as the public continues to demand access to this clean and affordable fuel.

The ExC Project is designed to meet the increased demand for natural gas in New York by adding compression and cooling equipment at existing compressor stations on Iroquois’ current system, an approach that efficiently adds capacity without expanding Iroquois’ pipeline footprint. Being developed entirely within the company’s existing pipeline system with no need to acquire any additional right of way, the Project avoids objections usually leveled against pipeline projects, such as impacts to landowners, wetlands, cultural resources, public recreational areas, important wildlife habitat, and surface water resources. The ExC Project is also designed to reduce gas emissions including carbon monoxide and volatile organic compounds.

NYAE supports New York State’s ambitious goals for a clean energy future. The ExC Project will not only improve access to natural gas to meet growing demand, it will do so with a cleaner energy source that is a critical foundation for that future:

  • Natural gas is helping to address climate change by lowering carbon dioxide emissions. While U.S. gas production is up 37% since 1990, greenhouse gas emissions are down 17%.
  • Cleaner-burning, domestic natural gas works in concert with intermittent renewable energy generation like wind and solar by providing reliable energy when such resources are not available.

Further, we believe that preserving the environment and delivering critical energy resources to New Yorkers do not need to be mutually exclusive goals. Consumers – families and businesses alike – need to be able to count on affordable, reliable energy. NYAE’s members also understand the important role that natural gas plays as a catalyst for job growth. The ExC Project is a smart solution that will ensure consumers get access to the energy they need.


Michael Lawler
Director, New Yorkers for Affordable Energy

About New Yorkers for Affordable Energy

New Yorkers for Affordable Energy is a coalition of community, labor, business and industry leaders from across the state who support greater access to clean, reliable and affordable sources of energy for residential and business consumers. We understand the important role that natural gas plays in our everyday lives, from heating and cooling our homes to powering our communities. As demand for energy continues to grow, New Yorkers for Affordable Energy supports efforts to increase access to natural gas for manufacturing facilities, power production, transportation, and to serve as a catalyst for job growth and support New York’s economy and quality of life.

Coalition Members

The Business Council of New York State, Inc.
New York State Building & Construction Trades Council
Acoustic Clean Dennis
Albany Valve & Fitting Co. Inc.
Ambient Environmental, Inc.
API New York
BlueRock Energy
Buffalo Niagara Partnership
Capital Region Chamber of Commerce
Central Hudson
Chautauqua County Chamber of Commerce
Chemung County Chamber of Commerce
Constitution Pipeline
Cortland County Chamber of Commerce
D.A. Collins
Danskammer Energy
Delaware Engineering
Dominion Energy
Eastern NY District Council of Laborers
Energy Coalition New York
Energy Equipment and Infrastructure Alliance
EnergyMark, LLC
Engineers Labor-Employer Cooperative (ELEC 825)
General Contractors Association of NY
Hudson Valley Building & Construction Trades Council
Independent Oil & Gas Association of NY (IOGA-NY)
Independent Power Producers of NY (IPPNY)
International Union of Operating Engineers Local 825 (IOUE 825)
IUOE Local 825
Joint Landowners Coalition
Laborers District Council of Eastern NY
Laborers Local 17 LECET Fund
Manufacturers Association of the Southern Tier
Millennium Pipeline
National Fuel Gas Company
National Federation of Independent Business
North Country Chamber of Commerce
NYS Building & Construction Trades Council
NYS Conference of the International Union of Operating Engineers
NYS Economic Development Council
NYS LECET Fund (Laborers-Employers Cooperation & Education Trust)
Orange County Partnership
Otsego County IDA
Penn-York Land Services Corp.
Unshackle Upstate
Upstate New York Laborers District Council
U.S. Chamber of Commerce’s Institute for 21st Century Energy
USA Compression
The Williams Companies

Testimony on National Grid’s Long-Term Natural Gas Capacity Report

March 31, 2020

Michael Lawler, Director of New Yorkers for Affordable Energy

Good evening  and thank you for the opportunity to testify.

My group, New Yorkers for Affordable Energy is dedicated to supporting increased access to cleaner, reliable, and affordable sources of energy for residential and business consumers. We’re a coalition of organized labor, business, and community leaders.

Our key message to you today is that we support your balanced approach to expand access to natural gas in New York City and Long Island by ensuring that you have the supply to meet consumer demand.

The long term steps that you have outlined strikes an important balance in the fight to reduce carbon emissions, while providing clean, affordable, and reliable energy.

Especially in critical times like these, where our hospitals are relying on natural gas to help power their emergency operations, we must rely on science and facts to guide our decisions, not just ambitious thinking by politicians and activists. Any realistic plan put forth by the City to reduce emissions must include new infrastructure for delivering natural gas – your plan does that.

A recent study by the Environmental Defense Fund supported the conclusion that there is a natural gas supply problem in New York City and the suburbs. Their “data demonstrates that those supply constraints, and they are pipeline supply constraints, are causing adverse environmental impacts.”

It’s also clear with the issuance of a recent executive order banning all new natural gas infrastructure, the mayor has given zero thought to how much this policy will really cost New Yorkers, or how it could make our housing crisis even worse. In short, for reasons I’ll explain more fully in a moment, we think the Mayor’s proposal is:

  • bad economic policy,
  • bad housing policy,
  • and an environmental policy that’s based on hopes, not reality.

I’d like to make three key points:

  1. No one knows how much it will cost to heat buildings with electricity in 2040 or how well that would even work, especially in winter. If the city requires electric heat that’s way more expensive to install and operate than proven natural gas systems, which will drive up rents and energy costs, making our affordable housing crisis even worse in New York.
  1. The mayor went ahead and announced an extreme, mandatory policy while three major feasibility studies have yet to be completed for your consideration. One study’s about the engineering and fiscal challenges of electrification. Another’s about how the electric grid needs to be upgraded. And the third, National Grid’s study, is about our city’s need for new natural gas infrastructure. Racing ahead and jamming through this policy before any of the studies are even done is classic ready-fire-aim, some may even say irresponsible.
  1. Finally we would suggest the city consider the situation at NYCHA. Over the last decade, the Housing Authority has spent millions to convert old, failing, dirty oil heat systems to clean-burning and much less expensive natural gas. The mayor’s executive order may force the authority to delay upgrading these systems which are essential for NYCHA residents.

The simple fact is that New Yorkers rely on natural gas. Sixty percent of New York households heat with natural gas, and 40 percent of our electricity comes from power plants that run on natural gas, according to the U.S. Energy Information Administration. Whether New Yorkers heat their homes in the winter or power their air conditioners in the summer, natural gas is fueling their everyday lives.

Additionally, according to the Western Energy Alliance, natural gas “is the number one reason the United States has reduced greenhouse gas emissions more than any other country.” The shift from dirtier-burning fuels like coal to natural gas has produced 57 percent more carbon-emission reductions than have all the renewable energy sources that have come online since 2005, EIA data show.

Now bear in mind, today only 30 percent of New York’s electricity comes from renewables. And 25 of that 30 percent is hydroelectric dams. Getting from 30 to 100 percent renewable by 2040 just for the energy we consume is a massive undertaking.

When the Indian Point nuclear unit shuts down next year, New York will need even more natural gas for power plants to fill the gap. Also, the more New York moves to intermittent renewable energy sources like wind and solar, the more vital it will be to have natural gas power plants online and available to cycle up as quickly as the wind stops blowing or the sun goes behind a cloud.

The truth is, natural gas is the only source of energy that can fully and reliably meet the needs of New Yorkers – and do so without increasing energy costs to homeowners and businesses or increasing the cost of new construction to alleviate New York’s affordable housing problem.

The City’s goal of converting every gasoline and diesel-powered car and truck in New York to electric and converting every building and home in New York now heated by oil or gas to electricity will require massive investments and years of infrastructure upgrades. Getting enough wind power and solar and other renewables built to cover all of that by 2040 will be incredibly challenging, very likely impossible.

If we could affordably live off nothing but renewable energy in New York in 2040, I think we’d all agree, it would be ideal and a dream to aspire to.

But if you look at where we are now, locking that in as a binding mandate, today is an incredibly dangerous policy. We don’t know if we can even do it, we have no idea how much it would cost, we have no idea what that would do to our housing crisis and the cost of construction. We haven’t even finished asking and answering those questions.

We are prepared to work with National Grid and the City of New York on developing a clean fuel future across the globe but urge all engaged to be realistic on how this can be best accomplished. Thank you.