By DOUG STOCK
The Dunkirk Area Labor Council writes to clarify the transmission proposal from National Grid that alleges to eliminate any need for the Dunkirk Power Plant after 2015.
We have the following questions and comments regarding the National Grid proposal:
NRG will file a response to the National Grid plan.
In a public document from 2012 that National Grid presented to the New York Independent System Operator, a major substation to be built in Southwestern New York was identified under subjects to address the potential loss of the Dunkirk Power Plant, yet the costs of this project alleged to be in the hundreds of millions and under construction, are not included in the National Grid proposal to eliminate the Dunkirk plant. Why not and how much will the substation cost ratepayers?
In addition to the 345kv to 115kv substation, a 115 kv line from the National Grid transmission system into Pennsylvania is identified as funded by First Energy in National Grid's project package to replace the Dunkirk site. It is safe to assume that these two projects would move power from Pennsylvania or Ohio at the same voltage and replace the output from Dunkirk. How much power will National Grid be purchasing from out of state and why is the cost not listed in their proposal?
Pennsylvania and Ohio are not Regional Greenhouse Gas Initiative states while plants like Dunkirk pays millions into the state greenhouse gas tax program. How is that fair competition?
National Grid criticizes NRG's listed greenhouse gas and other emission reductions from a natural gas conversion, claiming closing the plant will "reduce emissions to zero." Yet if we are importing coal power from non-Regional Greenhouse Gas Initiative states like Pennsylvania and Ohio, isn't National Grid's claim duplicitous at best?
Gov. Andrew Cuomo's visionary Energy Highway Blueprint includes an objective - now an active PSC docket 12-t-0502 - to upgrade aged state transmission systems and move at least 1,000MW of power currently stranded in Western New York into the New York City area - conservatively estimated by the New York Independent System Operator as needing an additional 200 MW of power per year for years to come. Wouldn't the proposal from NRG to repower Dunkirk - with superior short- and long-term economic impact - match up ideally with the transmission construction upgrades to move more power from upstate to downstate?
National Grid apparently had an oversight in not recognizing the Governor's Energy Highway objectives and instead detailed that surplus power from Dunkirk would have no place to go but into the "PJM system," yet it seems OK with National Grid to be advancing projects to move more Pennsylvania and Ohio power into New York?
Agencies such as the state Empire State Development and local IDAs provide incentives to manufacturers to locate in New York to grow jobs and tax revenues - regardless if their product is exported. How is it different with the manufacturing of electricity, and in the case of Dunkirk, have temporary or perhaps no power export at all depending on the Governor's Energy Highway objectives?
We urgently encourage the state Public Service Commission to carefully examine all the facts surrounding the Dunkirk Power Plant and the Dunkirk Area Labor Council looks forward to its response.
Doug Stock is president of the Dunkirk Area Labor Council.