To the Editor,
(July 5, 2013) – Light a candle: June was the one-year anniversary of the first request for an Issues Conference to resolve outstanding questions about United Water’s proposed Haverstraw Water Supply Project, a desalination plant to convert Hudson River water to drinking water. Since that first request was formally made to New York State Department of Environmental Conservation (DEC) by Scenic Hudson, the call for an Issues Conference has been made by Riverkeeper, the Rockland County Executive and Legislature, state legislators, four of five town governments, 12 villages, the Rockland Water Coalition and thousands of citizens concerned enough about unknown impacts of the project to have signed petitions.
Issues conferences are granted by New York State DEC, even for projects far less complex or controversial, when substantive and significant issues have been raised. If disputed issues are ignored and not resolved in a transparent process, all ratepayers -commercial and residential–may be adversely affected. Here’s why.
ECONorthwest, a respected economics, finance and planning organization, studied the cost sections of the DEIS prepared by United Water and found that the analytical deficiencies render the cost sections “almost useless” for those interested in independently verifying cost results-with the most significant omission being the lack of documentation regarding how the construction, operations and maintenance costs would impact ratepayers. (We did not have long to wait: United
Water made application to the Public Service Commission on June 14 for permission to begin collecting a New Water Supply Source Surcharge from ratepayers — and this is before the project is even approved or built.)
The ECONorthwest report concluded that failure to provide complete transparency in regard to costs calls into question the credibility of the DEIS as a source of information for those asked to make decisions regarding the approval of this plant, as well as for interested stakeholders. Specific concerns included the following:
· Limited documentation and analysis of current and future energy-related costs, including electricity to operate the plant and to pump water upslope from the river to the plant.
· Omission of the related cost of carbon emissions associated with energy demand for the project.
· Failure to use consistent measures and commonly-accepted industry standards to determine comparative costs for alternate projects that could achieve the same goals; the study concluded that the proposed project may not be the most cost effective solution.
· Estimates of construction costs included a $50 million variance (from $139 to $189 million) with no explanation.
· No information is given on how the uncertainty of the operating capacity could affect operating costs, and resulting costs on ratepayers. Not taking capacity into account increased operating costs for a desalination plant in Tampa, Florida, which also relies on brackish water.
Furthermore, there are a number of additional concerns, which must be addressed:
· New FEMA maps with Advisory Base Flood Elevations have recently been issued for the County in the wake of Hurricane Sandy to assess the flood risk for affected communities. Haverstraw is now defined as being in a high-risk coastal area in Zone V (Velocity). This means that it may be subject to a 12’ surge in a 100-year storm and 17’ surge in a 500-year storm. Hurricane Sandy was classified as a 500-year storm.
· A U.S. Geological Survey conducted for the county and completed in 2011 determined that the Newark Basin replenishes itself at sustainable rates. Peak water use during the summer can be addressed in a variety of ways far less costly than the proposed project.
· There has not been a thorough evaluation of the potential savings in terms of costs and water usage from a comprehensive conservation program. Aggressive water conservation programs, implemented in New York City and the State of Massachusetts, which included efficiency measures and infrastructure repair have successfully reduced per capita water usage, thus postponing or negating the need for costly projects.
· The implementation of an energy intensive solution–a desalination plant which requires electricity to pump water from the Hudson to solve the problem of occasional peak demand which has other non-capital solutions, which have not been equitably studied, is counter to Governor Cuomo’s sustainability agenda that seeks to address climate change and energy efficiency.
Why should UWNY customers embrace this project without having answers to the questions of costs impacting ratepayers? If facts matter and costs count, then all should join in the call for an Issues Conference.
Chairwoman, Rockland County Legislature