PSE&G Seeks Amendments To the NJ State Plan to Accommodate Wind Port At Delaware River Nuclear Complex

State Officials Must Leverage Their Regulatory Power To Secure Public Benefits 

Source: “Japanese Nuclear Accident And US Response” – NEI, Public hearing on (4/7/11 – Trenton)

I just got an email from the State Planning Commission staff regarding a petition by PSE&G to amend the State Plan map to allow their proposed wind port at the location of the current PSE&G nuclear plant complex on the Delaware River.

The petition is a large document and can be found here , hit the link and scroll down to the bottom under the heading: Map Amendment/Amendments under Consideration/Lower Alloways Creek,  along with a supplemental document that OPA requested PSEG to provide. There is an extended public comment period which expires July 9 and another period before a planned September 21, 2021 SPC meeting agenda.

Because I saw rather large omissions in the application – and because this application provides an opportunity to leverage broader public policy goals, including: 1) environmental justice; 2) improvements to Delaware Bay aquatic life currently slaughtered by the nuclear power plants; 3) renewable energy and demand reduction; and 4) even a Duck Island State Park – I fired off this quick note to the State Planning Commission staff.

PSE&G has not been shy in leveraging huge concessions from BPU – including blackmail to demand billion dollar subsidies of their nuclear plants:

‘The board is being directed to pay a ransom,’ said Commissioner Bob Gordon.

They’ve dodged billion dollar compliance costs for cooling towers for the nuke plants and are killing billions of aquatic life in Delaware River and Bay (under a dirty deal supported by leading NJ conservationists).  

PSE&G received a billion dollar “stranded asset” bailout under the 1999 energy deregulation law:

PSE&G, New Jersey’s largest utility was left with more than $3 billion of such stranded assets last year as a result of deregulation, says Busch.

The “lion’s share” of this total consists of the company’s Salem, Hope Creek, Peach Bottom and Limerick nuclear power plants.

Of this, Busch tells CFO.com, state regulators allowed for the recovery of $2.9 billion, $400 million through rate increases and the rest from the utility being able to write off the remaining life of the facilities.

PSE&G transferred hundreds of millions of dollars of cleanup costs for toxic pollution at old coal gas sites to ratepayers:

“PSE&G has determined that the estimated cost to remediate all MGP sites to completion could range between $431 million and $499 million,” according to their filing.

AND after all these ripoffs, they will make billions on their new  off shore wind monopoly.

So, Enough! State officials should shake the PSE&G money tree and secure compensation for public interests.

I would think unwinding PSE&G’s recent sale of the Duck Island power plant to a warehouse developer and development of a new urban waterfront State Park on Duck Island would be a small concession:

HRP envisions redeveloping the sites as state-of-the-art industrial parks to serve the growing need for regional warehouse-distribution hubs in central and northern New Jersey.

With all the growing opposition to warehouses, how has PSE&G kept this under the radar?

Greetings:

Please accept the following initial comments on the subject PSEG application. I reserve my right to submit detailed comments after a more thorough review of the application.

1) the petition repeatedly states that the project is done in cooperation and/or with the support of the NJ EDA.

The applicant should be required to specify the basis for these claims and clearly describe all NJ EDA financial, legal, technical, regulatory, and related support.

2. Attachment B states: (emphasis mine)

“Successfully implementing the strategies will result in a drastic reduction in New Jersey’s demand for fossil fuels with associated air quality benefits”

The applicant should be required to provide the regulatory basis and data to support and quantify for these two claims. What does “drastic” mean? What “air quality benefits” are contemplated? Traditional criteria pollutants and/or greenhouse gas emissions? Please quantify.

I’ve reviewed the BPU EMP and have not seen any linkage (in  regulation) between implementation of off shore wind and quantitative enforceable reductions in energy demand. Same concern regarding alleged air quality benefits.

In fact, I read the BPU EMP as suggesting just the opposite by emphasizing the compatibility of off shore wind and natural gas and integrating off shore wind with natural gas powered generation.

Is the applicant claiming that there will be a 1 -1 reduction in fossil generation for every megawatt of off shore wind? If so, how will this demand reduction be enforced?

3) I saw no discussion of the potential impacts on the nuclear generation complex, particularly regarding climate change driven sea level rise, storm surge, and Delaware River flood elevations.

Perhaps those issues are addressed in the DEP permitting processes, but they should be addressed from a planning perspective as well.

4) I saw no discussion of the oversight and risk issues under the jurisdiction of the Nuclear Regulatory Commission.

That is a significant gap that must be addressed.

I recall that there were NJ legislative hearings and other investigations in the wake of the Fukushima disaster regarding Delaware river elevations and the height of the intakes at these nuclear plants. These risks are magnified by climate change. Obviously, that critical issue must be addressed, particularly in light of climate change. See: “Japanese Nuclear Accident And US Response” – NEI, Public hearing on (4/7/11 – Trenton)

5) How will the overall project address longstanding concerns regarding cooling tower issues and fish and aquatic life kills?

6) I saw no discussion of the issues related to “environmental justice”. Gov. Murphy has issued Executive Orders and there is recently enacted “environmental justice” statute.

The applicant must be required to address numerous environmental justice considerations of this comprehensive project.

Given that the concerns I raise are fundamental, I urge you to suggest that the applicant withdraw the current application and resubmit a revised application that addresses these concerns.

Finally, PSEG recently shut down the Duck Island power plant. I understand that the PSEG Duck Island property was sold to a warehouse developer. Perhaps the SPC could make inquiry into this issue, and perhaps leverage a large “deal” whereby that land sale and development proposal could be unwound and the property donated to the State to form the anchor of a new urban waterfront State Park.

Respectfully,

Bill Wolfe