Civic Association Petitions for Natural Gas Supply to Broad Channel

Broad Channel Civic Association

September 7, 2011

Honorable Jaclyn A. Brilling, Secretary

State of New York Public Service Commission

Three Empire State Plaza

Albany, New York 12223-1350

RE: Case 11-G0358 Public Response to -Brooklyn Union Gas Company d/b/a National Grid NY Petition with Respect to the Application for Natural Gas Service by the Broad Channel Civic Association

Dear Secretary Brilling:

I am writing to you today as the president of the Broad Channel Civic Association to respond to the Petition for Relief filed by National Grid (KEDNY) on July 8 2011. I would like to start by asking that you honor the Limited Waiver Request submitted by KEDNY that would allow our civic association to be recognized as an “applicant” in this discussion. This would greatly expedite the matter of a formal application and enable us to move to the critical discussion of our request to have KEDNY provide this town with natural gas.

Broad Channel is an island community in Queens located within the waters of Jamaica Bay. We have been in existence since the early 1800’s. The town is comprised of approximately 925 residential homes and 50 businesses and is represented by the Civic Association. We have no access to natural gas and are currently the only area in the city of New York that uses 100 pound cylinders of propane. Over the years our community has repeatedly requested that gas service be provided from both the former companies of Brooklyn Union Gas as well as LIPA. These requests were denied with each company indicating the other should be looked to as the one responsible for the project. We have now engaged KEDNY as the sole supplier of gas to all our surrounding neighborhoods to request that they fulfill their obligation as specified under the Public Service Law 31, subd.4 and finally provide our town with a natural gas pipeline. We feel that this is not only a moral issue, no supplier that has a monopoly on the control of a necessary service should be allowed to pick and choose to whom they may want to supply based only on their economic return, but a safety and economic one as well.

The 100 pound propane cylinders that are currently used were previously clearly defined as allowable by the fire prevention directives that addressed their use. With the adoption of the 2008 building code and the subsequent creation of a new NYC Fire Code that defined allowance was removed and only a vague reference to such remains. We feel that with the extreme elements of winds and floods that this town experience’s the propane cylinders could eventually be involved in a situation of fire or explosion that would not be present if natural gas was an alternative. In addition there is a concern that any such situation would be followed by an outright ban, as is present throughout the rest of the city, and our residents would not have an option for home cooking requirements.

In regards to the economics of the situation we currently have no alternative to the use of #2 fuel oil for the heating our homes. As previously stated as an island community in the middle of Jamaica Bay we experience extreme winters and the fuel oil has continued to dramatically increase in cost while natural gas, a much cleaner fuel, has stayed almost constant due to the many new reserves that have been discovered domestically. Should fuel oil continue to rise many of our residents, particularly our seniors on fixed income, will be forced to suffer thru cold winter seasons.

We do not feel that NYCRR 230.2, cited in the KEDNY appeal, is relevant or applicable in our case and also that KEDNY routinely ignores such when undertaking other capital projects. Our town is not a new development that seeks to have a gas line supplied to it, often the case for such, but rather a community that should have received such service many years ago ,as all other adjacent neighborhoods did, but was denied such as the suppliers did not see an immediate economic return on their investment. This does not, in our view, justify their denial of that which is a basic necessity and one which every other resident of this city is afforded. In addition we would cite the example of the gas line that KEDNY is currently preparing to run from the Transco Williams pipeline, off the waters of the Rockaway’s, into Brooklyn as an example of such a project whose cost would not be borne by those of the lower Brooklyn area in need of such but rather shared by the entire customer base, as all such projects are.

Finally, while we thank KEDNY for submitting this application and the request for limited waiver, we do not necessarily agree with some of the assertions that it makes such as:

1) “825 homes converting to natural gas cooking; another 25 residential homes converting to natural gas heating and cooking” a. We submit that over time that many more, possibly all 925 home (not 825 homes), would seek to convert to natural gas for heating and cooking. 

2) “The pipeline would then continue for 11,300 feet in the Jamaica Bay Wildlife Refuge and then proceed 4,224 feet down Cross Bay blvd…” a. This pipeline would not have to pass thru the Jamaica Bay Wildlife refuge, an obviously environmental concern, as Crossbay Blvd, which is a city owned street runs directly thru the wildlife refuge and is city owned property.  

3) “and the fact that the main extension will not provide system benefits to other customers … a. The supply line run from Rockaway could continue north to Howard Beach to be used to augment that area where discussions indicated that growth has led to an issue of adequate supply. Such a concept would enable KEDNY to see additional benefits from the supply run.  

In summary we ask that the Public Service Commission deny this petition and mandate that KEDNY supply the community of Broad Channel with the Gas supply it so desperately needs.

Sincerely,

Daniel T Mundy,

President

Broad Channel Civic Association