GLEN HEAD - GLENWOOD - GREENVALE CIVIC COUNCIL

P.O. BOX 473

GLEN HEAD, NY 11545

 

 

Subject: Permit Application No. NAN-2024-00408-MMI — Opposition to New York Transco / Propel NY Energy Project:  Christopher W. Minck, U.S. Army Corps of Engineers, New York District Regulatory Branch

 

Re: Permit Application No. NAN-2024-00408-MMI — New York Transco LLC / Propel NY Energy Project

 

On behalf of our local Civic associations located in Glen Head, Glenwood Landing and Greenvale, New York, we are writing to oppose the New York Transco LLC / Propel NY Energy Project permit application.

 

Hempstead Harbor and Long Island Sound are not utility corridors. They are public waters used by residents, boaters, sailors, fishermen, shellfish interests, waterfront businesses, and surrounding communities. Any project involving submarine cable installation through these waters must be reviewed with the highest level of care.

 

Our members are particularly concerned about the disturbance of bottom sediments during trenching, jetting, cable installation, and related construction activity. The applicant’s own materials acknowledge that this work will disturb the seabed, create suspended sediment plumes, and resuspend contaminants such as arsenic, copper, mercury, and dioxins/furans. Given Hempstead Harbor’s industrial history, these impacts should not be minimized or treated as merely temporary.

 

Long Island Sound is a federally recognized Estuary of National Significance and part of the EPA’s National Estuary Program. Public agencies and local communities have spent decades working to improve water quality, restore habitat, support shellfish recovery, and protect public use of the Sound. It would be deeply troubling to approve a project that could undermine those efforts without a complete and independent review of the risks.

 

The Corps should also closely examine the applicant’s stated purpose. The permit application appears to describe the project as necessary to export offshore wind energy from Long Island. The application appears to be predicated on unreliable, non-resilient, costly intermittent wind energy that will not provide baseload energy needs and which is no longer in line with the evolving energy landscape on its face and should be denied until the applicant provides a full, consistent, and transparent explanation of the project’s actual purpose, need, alternatives, and cumulative impacts.

 

The Corps should not evaluate this application in isolation. Offshore wind, their new renewable transmission lines, new renewable substations, and battery energy storage are interrelated pieces of New York’s renewable-energy buildout but are being advanced individually as independent projects. Because all the pieces rely on each other for the build out to be fully functional, they should be considered as a single project. Glenwood Landing has already been identified as a location for a large scale BESS facility, and the newly expanded Propel substation footprint will be contiguous to said location sharing boundaries on the shore of Hempstead Harbor. Since the applicants purpose and need for the project is offshore wind export, the Corps should require the applicant to explain the battery energy storage component, as it’s a necessary reasonably foreseeable component of this renewable-energy build out. BESS is needed to support or stabilize intermittent wind generation and transmission, as such, the applicant should be required to identify where such facilities are expected to be located near Hempstead Harbor and interconnect in Glenwood Landing along with the cumulative environmental, fire-safety, runoff, emergency-response, and potential adverse water-quality impacts that would result.

 

For these reasons, and on behalf of our members, we respectfully request that the Corps deny the permit. Short of denial, the Corps  should require a complete independent review of the full extent of damage to Hempstead Harbor of all the interrelated facilities, transmission lines, batteries and substation which should include at a minimum: sediment disturbance, contaminant resuspension, turbidity, water quality, shellfish and benthic habitat, navigation, anchoring, burial depth, cable protection, boulder relocation, expanded substation infrastructure, potential future interconnection and reasonably foreseeable BESS-related impacts.

 

 

Thank you for your consideration.

 

Respectfully submitted,

 

George P. Pombar - President