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