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Monday, October 3, 2016

 Is the Article 10 process a fair Process?

October 3, 2016
Hon. Kathleen H. Burgess
Secretary to the Commission
Three Empire State Plaza
Albany, New York 12223-1350
Kevin Casutto
Presiding Examiner
Three Empire State Plaza
Albany, New York 12223-1350


RE: GALLOO ISLAND WIND, LLC. 15-F-0327


Dear Secretary Burgess and Presiding Examiner Casutto:


I am writing about two concerns I have about fairness of this process in evaluating the value of Galloo Island Wind LLC.
On an August 1, 2016 Governor Andrew Cuomo announced1, “The Clean Energy Standard will require 50 percent of New York's electricity to come from renewable energy sources like wind and solar by 2030, with an aggressive phase in schedule over the next several years (my emphasis).  The Article 10 siting process is the instrument by which the governor’s renewable energy plan will be implemented. The Article 10 Siting Board was given absolute power and authority deciding the merits of each energy proposal. The composition of the board is heavily weighted toward energy development, e.g., the Public Service Commission, NYSERDA and Empire State Development. Moreover, agency representatives are appointees of the governor and they have made public statements in support of his renewable energy agenda. For example, in the same August 1 news release the Chair of the Article 10 Siting Board, stated, “New York is now on its way to '50 by 30' and even more renewable power will be within our reach." When an “aggressive phase in” is added to this predisposed mix of officials we have a recipe that favors developers and one that ultimately will ignore environmental and local concerns. It is obvious the balance is tipped, their foot is on the accelerator and none of it is fair.
The other issue is demographic fairness. What has been lacking in the discussion of the Clean Energy Standard to date is how much we in upstate New York have contributed to renewable energy production so far and why upstate should not be targeted for the “aggressive phase-in” of the Clean Energy Standard. The Siting Board and the record in the case of Galloo Wind LLC need to have a clearer understanding of where electric demand is greatest and where future renewable energy generation is needed the most. If you examine the state’s usage and generation data, an imbalance is evident where upstate areas are near the finish line in the
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1 text.https://www.governor.ny.gov/news/governor-cuomo-announces-establishment-clean-energy-standard-mandates-50-percent-renewables
“50% renewables by 2030” race, and where downstate renewable development has yet to leave the starting blocks.

Turbine Map - NY.png

To quantify the imbalance, I used 2014 estimates of electric usage/demand reported by the New York Independent System Operator[2]. I combined NYISO zones G through K (Lower Hudson, New York City and Long Island) into a single downstate zone and compared it with the remaining upstate zones. I used the U.S. Energy Information Administration website to access the 2014 New York electric generation data[3], since the NYISO report provided no comparable generation data. Using EIA interactive mapping I was able to apportion the wind, solar and hydroelectric generation into upstate and downstate geographic areas 4.
As expected, the geographic distributions of electric usage and generation from renewable energy sources show a major imbalance in the area of renewable electric energy generation within the state:
 Table Schneider.png
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2 NYISO. 2015 Power Trends 2015: Rightsizing the Grid.  80pp.
3 http://www.eia.gov/state/?sid=NY
4 I used the proportions of  “Total Summer Net Capacity” for hydro and solar and applied it to EIA-NY’s Table 5 “Total power industry generation by primary energy source , 1990 through 2014 New York.”

Most of New York’s electric usage in 2014 was downstate, 58% of the total, but the area produces less than one percent of the power from renewable sources. In stark contrast, renewable electric generation in upstate represented 44% of the area’s usage. The renewable sources upstate in 2014 were composed of 87% hydroelectric, 13% wind and a trace from solar.  Hydroelectric resources, particularly Niagara and the St. Lawrence River, have long been major renewable energy sources for New York. The NYISO report had a higher estimate of 2014 renewable generation, 25%, although NYISO’s estimate also included generation from “other” energy sources.
These data reveal something that has been ignored in the discussion of the Clean Energy Standard – the unfairness in the siting of wind projects statewide. All wind projects are located upstate and combined with existing hydroelectric generation upstate communities are within easy reach of the governor’s goal of 50% renewables a lot sooner than by 2030. Downstate, by comparison, has not begun the process. The irony here is downstate residents consume 38% more electric energy, their elected officials adamantly support renewable energy policy, and at the same time there is no meaningful renewable energy production downstate. Furthermore, wind resources along New York’s ocean front are among the best in the state. Albany and downstate officials seem content to focus all renewable development on upstate communities to reach the governor’s goal of 50% renewables by 2030. It is obvious demographic fairness was never considered in the governor’s news release on August 1, 2016.
To be more impartial, the Siting Board should reject the governor’s charge for an aggressive phase-in of renewable projects in upstate areas, particularly in communities where proposals adversely impact sensitive environmental resources, such as Galloo Island, and where communities do not support project proposals. Instead, aggressive development efforts should be directed downstate. The focus upstate should be to protect valuable resources and communities and not diminish their importance in the name of an “aggressive phase-in” of the Clean Energy Standard.
Sincerely yours,
Clifford P. Schneider
Pro Se

3 comments:

Art Pundt said...

I like your comments here Clif. Glad to see you are recognizing what Art 10 is about.
However, despite your recognition of the problem of Art 10 being rigged and unfair you are still giving input into a rigged unfair system that if it is rigged and unfair is highly likely to ignore your input. That too is what Art 10 is designed to do. Get around local laws, tightly control and manage and marginalize input.
Since a siting baord can override local laws and thus any input as well as I think you found out with the DEC response to your Galloo concerns. Sorry we heard your input but we disgaree and are going to participate anyhow!

And sadly Art 10 reaches deeper with preemption. It essentially has the power to neutralize your elections and elected officials and their decisions and laws.

Time for a new approach than to appease and enable such abuse of our rights.

Anonymous said...

Art Pundt is typical of the downtrodden who has no guts to
stand up to government and no courage to fight them
using the public record which Article 10 is developing.
Unless of course Art Pundt is working for
the developer when he criticizes Schneider for his hard
work and input. Which might be true since right now there is
a concerted assault on Art Pundt's neighborhood to put
wind mills which violate the local law while Art Pundt is nowhere
to be seen. With his silence on the issue in his own neighborhood
he is showing his true colors and throwing his friend and ally Hester
under the bus.

Art Pundt said...

No courage to fight govt using the public record? Really? This demonstrates just how completely out of touch with really you are.

Apparently your memory is very conveniently selective in forgetting that it was myself and a few others against great odds that convinced Cuomo when he was NYAG to come to CV and do an investigation of wind conflicted officials.

That investigation created critical leverage for other CV people to run for office and defeat the old CV wind conflicted govt. and focused a lot of attention on CV and just how unethical the entire wind disaster is. Were you asleep back then????

About Mr Schneider...can't you read? I have applauded Clif for his work concerning the DEC conflicts and his comments on Art 10 here and in other media. To me he has exposed considerable concrete evidence that the DEC and the Art 10 process are heavily rigged. My point is that if you know the system is rigged then why engage in it, rather than look at another approach. Clif confronted the DEC and Art 10 and they simply ignored him. It defies logic for you to think you can influence a system that has already proven it will ignore your input.

When you refer to "neighborhood I am not sure which you are speaking of, CV or Clayton? But you should get a grip that both towns have zoning the actually ALLOWS wind development, and in CV several former and current town officials have put it on the record that they did not write the law to STOP wind development! You are right I have not interest at all defending a law that appeases the state Art 10 system enabling the state to violate our home rule rights, or that will allow some type of wind development. If they want to actually ban wind I will be behind any such effort!

Oh and finally...anyone who can't find enough spine to put their name on a post should not be talking about anyone else's "courage" or "guts". And the real hoot is you talk about a "public record" yet as anonymous you leave NO RECORD!!! I have taken a lot of heat for my stance and so be it. But you as anonymous can run and hide since apparently you can;t take the heat!