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Champlain Hudson Power Express: Comments from the public

Roberta Frampton Benefiel Grand Riverkeeper Labrador, Inc.

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Communities, organizations and individuals are urging New York State not to award billions of dollars in clean energy subsidies for the Champlain Hudson Power Express (CHPE) hydropower transmission project, based on numerous concerns. Together, we demand better.

Riverkeeper is among many voices calling on Governor Hochul and the Public Service Commission to reject the use of “Tier 4” renewable energy credits for the Champlain Hudson Power Express, a project that would bring Canadian hydropower to New York City through cables buried in Lake Champlain and the Hudson River. This destructive project raises numerous concerns. There are better alternatives that have lesser impacts and far greater benefits.

Find an overview at, and read on for excerpts of public comments submitted to the PSC.

Read Riverkeeper’s formal comments regarding the proposed Tier 4 contract award to CHPE, submitted to the Public Service Commission February 7. Excerpt:

“The CHPE project fails to meet the most basic requirement of a clean energy project, because it will not directly reduce greenhouse gas emissions and it will continue to emit greenhouse gases after 2040, when New York’s climate laws require the electric grid to be emissions free. Adding insult to injury, this project would take up billions of dollars in taxpayer subsidies that should be paid to a project that would reduce greenhouse gas emissions.

Compounding the many negative impacts associated with this project, giving Hydro-Quebec a lucrative contract could induce the building of more dams and further injure Indigenous peoples who have already been gravely injured by past and ongoing dam construction. More locally, using the Hudson as a conduit for an electric cable threatens to stir up PCB laden sediments, potentially damaging drinking water supplies, interfering with fish migration, and affecting shipping.

Riverkeeper had negotiated a settlement with the developers of CHPE nearly a decade ago, when it was seen as an essential alternative to Indian Point, which had devastated the river ecosystem and put local communities at risk for generations. We have had the courage to take a second hard look at this project, in light of the alternatives available, and essential facts that have since emerged, including the dire and multifaceted impacts of hydropower. The PSC, too, must take this hard look and change course before it wastes billions of taxpayer dollars on a false climate solution that violates environmental justice principles.

For these reasons, the PSC should reject NYSERDA’s choice of this flawed project and instead urge NYSERDA to select a proposal that utilizes renewable resources other than hydropower, preferably generated in New York, and one that has selected a route that minimizes the use of the Hudson as a conduit for the cable.”
Richard Webster, Director of Legal Programs, Riverkeeper

Read Riverkeeper’s “reply comments” submitted February 21.

Other public comments:

“We have long advocated that Canadian hydropower is a false solution for New York City’s climate justice goals. The results of the Tier 4 auction, which showed the competitiveness of in-state solar, wind, and energy storage based proposals, reaffirms our position. We echo the comments filed by the Sierra Club, Riverkeeper, the Duchess County Legislators, and others that CHPE is not the answer for New York City’s electricity transition – we can and should do better.

“A second solicitation that properly values in-state and in-City climate solutions will provide more benefits – including employment, investment, environmental benefits – for both the state’s ratepayers and City residents. There is no need to approve CHPE’s offer when the State has access to better options that will actually result in transitioning New York City from fossil fuels to renewable energy.

“For all of these reasons, the NYC-EJA urges the Commission to pause before it acts with respect to CHPE, and consider the opportunity cost of approving this expensive project that actually decreases the net societal benefit to the state. The Commission can deliver better justice to the communities we represent by not approving the CHPE contract, and instead ordering NYSERDA to run another solicitation that gets better value for the state and for the NYC communities that need those benefits so badly.”
Eddie Bautista, New York City Environmental Justice Alliance

“Water to us is life. We drink it, and we eat the fishes that come from those waters. And those waters, many of them, are within dams. Some of them are small, some of them are bigger. But this is something that people need to know in New York, and the authorities need to understand what are the impacts that we live every day.

“I represent five communities … it’s about 8,000 people. At least half of them live beside those waters, or near those dams. So we have impacts. Our people are affected by this. Fishes have some effects, because of the mercury that fish have in their bodies, and still our people eat those fishes. And we consider ourselves the forgotten ones, the ones that people don’t talk about, because Quebec government, Canada or Hydro Quebec are trying to ignore our people and our rights as human beings.

“You need to know where the energy comes from. It doesn’t come from the line. It comes from the dams – and this is where we are – near the dams, and where our territories are, unceded – and this needs to be understood. You have people from New York and the authorities have that power to obligate stakeholders, proponents, to really look at this seriously and find solutions with us, not behind our backs, not with only Hydro-Quebec. We need to be part of the discussion, we need to be there. We are here. Please don’t ignore, people, please don’t ignore our rights.”
Lucien Wabanonik, elected councilor with Lac Simon’s band council in Quebec

“Greenhouse gas emissions from all sources impact the entire globe. Climate Change will not go away from New York because you ignore emissions from plants operating in Canada and providing power over CHPE.

…Replacing dirty fossil fuel plants in New York with dirty hydro in Canada is unethical, and better alternatives exist. We implore you, please, review the science and other evidence we have provided on the environmental issues and environmental justice issues and reject the request of Hydro Quebec/US-Transmission Developers Inc to obtain Tier 4 credits for the Champlain Hudson Power Express.”
Roberta Frampton Benefiel, Grand Riverkeeper Labrador

“While the CPNY [Clean Path NY] project will provide significant benefits to New York, the same cannot be said of the CHPE project, particularly given the specific terms of the proposed contract. The CHPE contract fails to include a Supplier Energy Baseline and therefore risks forcing New York electric customers to pay more for hydropower that would have otherwise been delivered into the NYCA… The Commission should approve the proposed contract for CPNY, reject the proposed contract for CHPE, and authorize NYSERDA to negotiate a contract with a second in-state transmission line.”
Sierra Club

“Hydro Quebec Project does not guarantee delivery of Tier 4 RECs in the winter, despite the fact that NYISO modelling predicts that New York’s peak electricity demand will shift to the winter as building electrification progresses. Again, we assume that a winter guarantee of delivery was not included due to cost considerations, but we also assume other bidders would have provided this benefit… The public should be better informed of the rationale for the selection of the Hydro-Quebec project with this characteristic, given the expectation that increased capacity market revenue would reduce NYSERDA expenditures for Tier 4 RECs under the indexed REC contract structure.”
Alliance for Clean Energy New York, Inc

“I have no objection to hydropower produced from run-of-river operations that do not impound vast areas of land, but the vast flooding and destabilization of water levels over thousands of acres of once-productive wetlands outside of New York is not a sustainable solution to the state’s energy needs. Moreover, it is essential that New York now account for the greenhouse gas emissions that result from flooding boreal forest and coastal wetlands, and from hydropower operations.”
Bryan Swift, former Wildlife Biologist at New York State DEC

“Even though the reported purpose of your project is to provide renewable energy to NYC, this does not mean you can ignore the new environmental impacts on the communities introduced by Tier 4 contracts. Renewable energy transmission lines and their construction have clear impacts on the people, the natural resources and the habitat of the people of the Bronx. Contracts have been awarded and may be approved without completing environmental impact statements on the impacts of citing newly awarded and already approved contracts in the Bronx and its waterways. In the final analysis, it does not make the Bronx environment better, as there is not even a commitment to closing the ‘peakers.’
We find that the completed environmental reviews, however extensive for upstate communities, and even NYC at large, have not reached the appropriate level identifying critical impacts on the Harlem River from the Hudson River to the East River.”
Karen Argenti, Secretary and Robert Fanuzzi, President, Bronx Council for Environmental Quality

“We, the undersigned of the Dutchess County Legislature – who care deeply about the Hudson River, climate, and environmental justice – urge you to reject the awarding of Tier 4 renewable energy credits for the Champlain Hudson Power Express.”
Dutchess County Legislators

“GELF urges you to reject the CHPE proposal as a false solution to the renewable energy goals of NY State and to our goal of reducing NY State’s contribution of greenhouse gases to the global climate.”
Mark Dunlea Esq., Chairperson, Green Education and Legal Fund

“Our organization is strongly opposed to this project, as a direct threat to our health by re-suspending PCBs and other contaminants into the water column. As a resident of the Town of Rhinebeck, I further see a direct threat to myself and my family as direct consumers of Hudson River drinking water. Withdraw support for this project until alternative transmission locations (not in the Hudson River) can be proposed.”
Commodore Robert S. Wills, Hudson River Ice Yacht Club

“As a Steering Committee Member of Newburgh Clean Water Project, a volunteer environmental group representing approximately 800 locals, I’m writing to express my concern about the Champlain Hudson Power Express plan to jet plow the Hudson River. We’re aware that testing is being conducted on the effects of the sediment plowing, but until the results of these tests are known, it’s premature to grant such an order. We’re also concerned about the nature of this energy generation and whether it contravenes indigenous rights at source in Canada.”
Tamsin Hollo, Newburgh Clean Water Project

“There is much at stake. Hydro Quebec and the Quebec Government’s long lasting violation of our rights is such as our First Nations are slowly being destroyed, as Canadian Government socio-economic statistics indicate. Our socio-economic indicators are comparable to those of third-world countries.”
– Savanna Algonquin, Acting Chief Algonquin Anishinabeg Nation Tribal Council

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