Urge the PSC to deny CHPE's construction plans for a more shallow burial of transmission cables in the Hudson River

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Urge the PSC to deny CHPE's construction plans for a more shallow burial of transmission cables in the Hudson River

In 2013, the NYS Public Service Commission (PSC) approved CHPE’s proposed project to construct and operate an energy transmission line from the New York/Canada border to a converter station in Astoria, Queens. The project includes two five-inch diameter cables that will be installed underwater or underground along the approximately 339-mile-long route. Prior to beginning construction on each portion of the project, CHPE must submit an Environmental Management & Construction Plan (EM&CP).

On April 8, 2024, CHPE submitted the draft EM&CP to install approximately 90 miles of submarine cables in the bed of the Hudson River, which is anticipated to occur in two phases in 2024 and 2025. Four miles of cables would be placed within the navigation channel. The EM&CP for the Hudson River cable installation segment of the project details how this part of the project will be constructed. It must be reviewed and approved by PSC before construction on this segment can begin.

Unfortunately, the draft EM&CP submitted by CHPE for the Hudson River cable installation segment of the project fails to adequately address environmental, public safety, and navigational concerns. Join Riverkeeper in urging PSC to deny CHPE’s EM&CP and require additional procedures, studies, and plans to better protect the Hudson River and the fish within it, vessel operators, and the public.

The deadline for submitting comments is May 13, 2024.

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Hon. Michelle L. Phillips, Secretary, Department of Public Service

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On April 8, 2024, the Champlain Hudson Power Express (CHPE) filed its draft Environmental Management and Construction Plan (EM&CP) for the Hudson River cable installation segment of the approved CHPE energy transmission project. The EM&CP for this segment provides detailed information regarding how this segment of the project will be constructed, the specific locations of the proposed route, and descriptions of work to be performed. However, the draft EM&CP submitted by CHPE for the Hudson River cable installation fails to incorporate a fair and thorough public outreach process and adequately address environmental, public safety, and navigational concerns.

To protect public safety and minimize impacts on the environment, the draft EM&CP for the Hudson River cable installation segment of the project must be revised to address the following concerns:

Public Involvement: 
Installation of the cable in the Hudson River will directly impact many communities located along the 89.3-mile route. CHPE's Public Involvement and Compliance Plan fails to identify the counties and municipalities that lie adjacent to the portion of the Hudson River where the cable is to be installed as "Impacted Municipalities." There is no question that cable installation in the Hudson River will directly impact these river communities and the millions of people who live, work, and play in the Hudson Valley.

In addition, the list of "Local Municipalities" included in CHPE's Public Involvement and Complaint Resolution Plan is missing the contact information for several key riverfront communities, including: Town of Germantown, NY; Town of Orangetown, NY; Town of New Windsor, NY; City of Peekskill, NY; Village of Wappinger Falls, NY; Village of Nyack, NY;  Town of Ossining, NY; Village of Tarrytown, NY; Village of Hastings on Hudson, NY; Village of Ardsley-on-Hudson, NY; Village of Piermont, NY; Bergen County, NJ; Borough of Alpine, NJ; Borough of Tenafly, NJ; and Borough of Englewood Cliffs, NJ. These communities base their economic growth and development on the Hudson River. CHPE must make certain that the list and contact information provided in the Public Involvement Plan and Complaint Resolution Plan is complete to ensure that impacted communities are getting the necessary information and notices.

Furthermore, CHPE's Public Involvement and Complaint Resolution Plan states that CHPE will host two in-person open houses, one on each side of the Hudson River, to allow residents to review project details and speak to CHPE construction and engineering team members. Two meetings are not enough to cover the extensive, almost 90 miles of cables. CHPE must host additional meetings to give the public ample opportunity to attend. CHPE should also consider adding virtual options for meeting attendance to maximize access and public outreach. In the past, notice of CHPE's in-person meetings has been difficult to find. As such, CHPE should be required to post notices of its meetings on its website and on the case docket.

Navigational Safety: 
On February 9, 2024, CHPE submitted a petition to reduce the required burial depth of the cable in the navigation channel of the Hudson River from 15 feet to 9 feet. The NYS Public Service Commission has not yet issued a determination on this matter, but CHPE's EM&CP for the Hudson River cable installation segment assumes that its request will be approved and includes only a design to install the cable just 9 feet below the navigation channel.

Allowing the 9-foot burial depth would substantially increase the potential for a catastrophic break of the cable due to an event such as anchor snag from the substantial commercial shipping traffic that traverses the Hudson River. As a result, the reduced depth would complicate responses to navigational emergencies like the one that caused the recent Key Bridge collapse. The burial depth of the cable is a critical issue for the public. CHPE's EM&CP must include design and cable installation details for installing the cable at least 15 feet below the federally maintained navigation channel to comply with its Certificate.

Conclusion
The Hudson River is an invaluable resource for its ecological productivity, economic importance, and irreplaceable historical and cultural value. I am frustrated with CHPE's inadequate public outreach efforts and greatly concerned about the imminent navigational and environmental risks associated with the cable installation in the Hudson River. I urge the commission to deny CHPE's EM&CP as submitted and require additional procedures and requirements to better protect the Hudson River, vessel operators, and the public.

Thank you,
[Your Name]
[Your Address]
[City, State ZIP]