Public Hearing
November 13, 2002
Tarrytown Hilton

Federated Conservationists of Westchester County, Inc.(FCWC) is a 36-year-old organization founded by many organizations and individuals to create a unified voice on environmental matters of regional concern. For the last 36 years FCWC has worked on protecting wetlands, habitat and parks, ensuring adherence to environmental regulations, and protecting and enhancing Westchester's natural resources: the Hudson River, Long Island Sound and the New York City watershed.

I am here to urge that the Department of Commerce deny Millennium Pipeline's appeal and refuse to override the objection of the New York State Department of State which found that the proposed route of the Millennium Pipeline is inconsistent with the Coastal Zone Management Act. I do not want to dwell on the legal arguments relevant to this review as they are covered in the many papers submitted on this appeal.

The briefs submitted fully explore the fact the Millennium Pipeline project does not further the national interest. The project creates an enormous risk to the New York City water supply. It is hard to imagine how putting the drinking water of that critical metropolis at risk would serve the national interest. The project does not even serve a demonstrable regional need. The New York State Energy Plan published in June of 2002 states that New York has adequate gas supply to "meet all generation scenarios."

The briefs submitted cover at length the severe coastal consequences that can be occasioned by constructing a pipeline within two feet of the Catskill Aqueduct and the damage to the watershed that will be inflicted by the pipeline as proposed.

The briefs submitted review the lack of exploration of alternatives by the Millennium Pipeline proponents and the existence of several viable alternatives.

I want to speak to the process:

There is no master energy plan here:

• No one is looking to see what the long term regional energy needs are.
• No one is analyzing where it is best to site energy infrastructure with minimal damage to coastal zones, watersheds and other critical natural features.
• No one is examining whether existing infrastructure can be utilized to meet energy needs even if it requires free enterprise competitors to work together cooperatively to protect the environment.
• No one is reviewing whether there are energy technologies available that may have a higher first cost but would be preferable in the long term based on overall costs including the cost of environmental degradation.

We have only one environment. That environment must nurture and support us for all time. Protection of that environment must be a paramount consideration.

Despite the fact that energy infrastructure often imposes enormous negative environmental impacts, we are living with a deregulated energy system governed by the process we are dealing with here today. Development of energy infrastructure is driven by proposals put in by private companies with routes plotted with the profit motive as the motivating force. The constraint imposed on that free market process are laws like the Zonal Coast Management Act which can block damaging proposals. Without an overall energy plan, adherence to findings pursuant to laws that do exist to block siting and development harmful to the environment are crucial to the rationality of the process.

What we have here today with respect to the Millennium Pipeline is a compelling finding of inconsistency with the Coastal Zone Management Act. What we have here is opposition from New York State, New York City, Westchester County, local governmental units, and an overwhelming number of local citizens.

On the facts here the federal authorities should defer and not override a local finding of an inconsistency with the Coastal Zone Management Act. Once the pipeline is built the damage is irrevocably done and those who live in New York are the ones that will suffer.

Thank you for the opportunity to present our views.

Edna Sussman