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We, the undersigned residents of the State of New York,  hereby request that the New York State Public Service Commission: 


Many new transmission lines projects are proposed for the Hudson Valley to allow upstate surplus electricity to be sent down state to New York City and Long Island. These new 'monster' transmission towers will blight the Hudson Valley for centuries to come. We must act now, and demand that new lines are placed UNDERGROUND or are installed on existing towers, setting the precedent for decades to come, preserving the beauty and health of the Hudson Valley, and meet the needs of New York City. Underground cables will greatly increase the reliability and security of electric service to New York City and gain exemplary protection from ice storms, hurricanes like Sandy, terrorist attacks and the extraordinary future savings of maintenance and emergency repairs.

The Response to Governor Cuomo's Energy Highway Initiative - to supply New York City with much needed and lower cost electricity and to possibly reverse the impending $340 Million/yr FERC Capacity Zone Rate hike in the Hudson Valley/NYC region - has produced four proposals to build a major new transmission line. 

ONLY ONE of the four projects could be rapidly permitted, and quickly built with few or no intervenors, requiring less than 50 miles of new work to solve the problem -  proving to NYSIO and FERC that the rate hike is not needed  ( see Senator Chuck Schumer’s letter to FERC Chairman Jon Wellinghoff below)

Three would use traditional overhead lines that require new taller 'monster' towers and new land for right of way (ROW) incurring extravagant costs  over hundreds of miles of congested ROW.  These three proposals would be fought by all those Residents through whose property they must pass and whose property would be taken by Eminent Domain. This would also extend the period of Crippling  Property values - which is already well underway - for many more years.

The fourth, from a group of non-traditional utility engineers, uses undergrounding and high tech cable to remain less expensive and avoid new towers or land taking, and becomes nearly storm proof - but presently has no political patron. 

We must work together across the Hudson Valley Region and New York City to let the Governor know that his plan has a quiet disciple:  Boundless Energy ( the small group of innovative Engineers who designed the underwater/underground Neptune line that was built in 2007 for $660 M and now carries 20% of all of Long Island's power - safe under the sea bottom and never touched by Sandy! THIS IS WHAT THE PEOPLE OF NEW YORK STATE WANT FROM THEIR LEADERSHIP IN NEW TRANSMISSION PROJECTS 



A copy of Schumer’s letter to FERC Chariman Jon Wellinghoff is below:

Dear Chairman Wellinghoff,

I write to urge the Federal Regulatory Commission (FERC) to delay the New York Independent System Operator’s (NYISO) proposed tariff revisions to establish a new capacity zone (NCZ) until at least 2017. As it stands, the NYISO plans to implement the NCS by May 1, 2014 to coincide with the start of the 2014/2015 capability year. Though the stated purpose of this NCZ is to increase electricity prices as a means to attract more investment in power generation to address reliability constraints in the region, the capacity zone does not account for new transmission initiatives underway that form part of New York State’s Energy Highway Blueprint that will address the deliverability constraint identified by NYISO.  The State of New York’s plan to build major transmission facilities by the summer of 2016 will have a material impact on bulk power capacity in the corridor has identified as congested and will eliminate the need for price increases for ratepayers that may be upwards of $350 million per year.




NYS “Energy Highway” Initiatives, Due For Completion In 2016, May Alleviate Power Constraints on Hudson Valley– Schumer joins PSC and Others to Urge Fed. Energy Regulation Commission to Delay New ‘Capacity Zone’ until Upgrades Can Be Quantified and Assessed

FERC’s Proposed New Zone Would Raise Prices Between 6 and 15% for Ratepayers in the Hudson Valley, Cost Over $350 Million Annually

Schumer to FERC: Changing the Power Grid Now is Jumping the Gun – Wait for Transmission Upgrades to Be Completed Before Making Any Zoning Changes

Today, U.S. Senator Charles E. Schumer urged the Federal Energy Regulatory Commission (FERC) to delay their order to implement a new capacity zone that covers a significant portion of the Hudson Valley power grid – a move which could result in a rate increase of between 6 and 15 percent for Hudson Valley ratepayers, or over $350 million annually – until they can assess the impact of in-progress transmission upgrades.  FERC and the New York State Independent System Operator (NYSIO), which operates the state power grid, have proposed a new capacity zone in the grid which includes Orange, Ulster, Rockland, and Sullivan Counties in an attempt to alleviate power constraints in the area by increasing prices to attract new power generation capacity. 

Schumer today joined the NYS Public Service Commission (PSC) and the New York Power Authority (NYPA), among others, to call for a delay in the new zone until transmission upgrades recently approved as part of New York State’s Energy Highway Project could be realized and assessed. Schumer explained that transmission projects approved by the PSC are set to be completed in 2016, and are projected to create upwards of 600 megawatts of power by moving energy more efficiently to the Hudson Valley and New York City.  Schumer said that FERC’s new zone would preliminarily jack-up the prices for ratepayers in advance of the completion of these projects that will help relieve the initial problem, and perhaps eliminate the need for a new zone. 

“While we need to find better and more creative ways to alleviate the power constraints on the Hudson Valley and New York City, FERC’s proposal for a new zone is jumping the gun – it would increase the burden on ratepayers before other efforts to solve the problem can be completed,” said Schumer.  “That’s why I’m asking FERC to delay their implementation of a new capacity zone until at least 2017, when we can properly assess the impact of in-progress transmission upgrades. These upgrades may lead us to a solution that doesn’t include a proposal that would, in the short-term, line the pockets of existing power generators without a substantive increase in power generation.”

The FERC and NYISO order would create a new capacity zone in the power grid that stretches from New York City to Albany in an attempt to alleviate a transmission bottleneck.  Currently, there is a surplus of cheaper power generated Upstate that does not reach energy-needy areas in the Hudson Valley and New York City in an efficient manner.  The new zone is designed to increase electricity prices to attract new power plants to the region; estimates by the New York Dept. of Public Service (NYDPS) put the annual increase of cost at $350 million.  Orange and Rockland Utilities customers may face a 6 to 10% increase in prices, residents in Central Hudson’s area could see a 10% increase, and large industrial ratepayers could see as much as a 15% increase in energy prices.  Schumer noted that although he supported finding new energy sources for Hudson Valley residents, he does not support doing so on the backs of ratepayers if, as in this case, other options exist to deliver the needed power more efficiently and cheaply.  Schumer expressed concern these large rate hikes could have on small businesses and employers throughout the Hudson Valley. For many companies, such a large spike in energy costs could decrease job creation and expansion efforts at a time when the local economy is on the track for economic growth.

Furthermore, he pointed out that transmission upgrades proposed by the New York State Energy Highway program, which are approved by the PSC and set to go online in 2016, are specifically designed to deliver power around the bottleneck to Hudson Valley customers.  One such project is an $11 million investment in transmission upgrades running from Central Hudson’s Rock Tavern substation to Con Edison’s Ramapo substation in Rockland County.  Schumer explained that it made no sense to jack-up the rates on residents now, before such efforts could be completed.

Schumer argued that the current proposal would undermine statewide efforts to increase the efficiency of transmission and delivery systems, and unfairly hike rates before any new power generation could be achieved.  Schumer said that, at the very least, in the event the new zone moves forward, rate hikes should be delayed or phased-in.  As it stands, Hudson Valley consumers would see skyrocketing rates even before prospective energy developers could move-in and help increase power generation.

The new capacity zone is set to take effect in May of 2014, and Schumer is seeking a delay until 2017 at minimum, or until the transmission upgrades from the Energy Highway initiatives can be properly assessed.



New York seeks delay of costly FERC power capacity zone decision

Sept 26 Thu Sep 26, 2013 12:23pm EDT

(Reuters) - New York utility regulators and some of the state's power companies asked federal energy regulators to reverse a recent decision that the New York parties say could increase electric bills in the Lower Hudson Valley by $350 million a year.

The New York State Public Service Commission (PSC) and the state-owned New York Power Authority (NYPA) said in a press release on Wednesday that the proposed new capacity zone in the Lower Hudson Valley could result in theconstruction of unnecessary new power projects.

The PSC, NYPA and other New York utilities asked the U.S. Federal Energy Regulatory Commission (FERC) to reconsider its August decision allowing the state's power grid operator, the New York Independent System Operator (NYISO), to create a new capacity zone in the Lower Hudson Valley that includes New York City.

The NYISO has said it designed the new capacity zone to maintain system reliability and attract investments in new and existing generation and demand response resources.

In basic terms, capacity markets pay generators to help keep existing power plants in service and build new units in order to maintain system reliability. Demand response providers who agree to reduce power usage when needed can also participate in capacity markets.

The new zone will include the current NYISO zones G, H and I in the Lower Hudson Valley and zone J in New York City.

The PSC and NYPA said the state is already working on New York Governor Andrew Cuomo's so-called Energy Highway initiative to expand the state's transmission resources to bring more power from upstate New York to the Lower Hudson Valley and New York City area.

The PSC and NYPA said the Energy Highway could negate the need for FERC to offer financial incentives to build more power plants downstate.

"We strongly urged FERC to reconsider its decision to create a new capacity zone in New York, which it says is needed to build more power plants downstate to alleviate demand for electricity," PSC Chairwoman Audrey Zibelman said in the release.

"We are well aware of the downstate demand for electricity...However, in its decision, FERC did not take into consideration the ongoing initiatives included in the Governor's Energy Highway," Zibelman said.

The biggest power companies in New York include units of Consolidated Edison Inc, National Grid Plc, Iberdrola SA, Entergy CorpTransCanada Corp and NRG Energy Inc.


The PSC said if FERC's plan goes into effect, typical residential customers in the Lower Hudson Valley could see monthly bill increases ranging from 5 percent to almost 10 percent, depending on the utility. The increases for industrial and commercial customers could be even higher, the PSC said.

"Creation of a permanent new capacity zone undermines the Governor's Energy Highway initiatives," Gil Quiniones, NYPA president and chief executive, said in the release.

"The Energy Highway pursues a long-term solution to deliver lower-cost, upstate power to the downstate area by reinforcing the transmission system, Quiniones said, noting the new capacity zone will "take money out of the pockets of ratepayers and result in a windfall of profits for existing power plant owners in the region."

The NYISO plans to implement the new zone by May 1, 2014. The PSC is asking FERC to delay implementing its decision until 2017 and consider how the Energy Highway proposals will affect long-term power prices.

"Without such analysis, FERC cannot properly assess whether it is causing more harm than good, and whether consumers might end up paying hundreds of millions of dollars for unneeded power plants," the PSC and NYPA said.

Governor Cuomo proposed the Energy Highway initiative in January 2012 to rebuild the state's power system by adding up to 3,200 megawatts (MW) of generation and transmission capacity and clean power.


One megawatt can power about 1,000 New York homes.