Client: New York Lawyers for the Public Interest and Earthjustice
Authors: Bryndis Woods, PhD and Liz Stanton, PhD
September 2021
On September 13, 2021, New York Lawyers for the Public Interest and Earthjustice—on behalf of the New York City Environmental Justice Alliance, THE POINT CDC, UPROSE, Chhaya CDC, and Clean Energy Group, together with Sierra Club—submitted comments to the New York State Department of Environmental Conservation (DEC) regarding the Draft Title V Air Permit and the Draft Supplemental Environmental Impact Statement for Astoria Gas Turbine Power LLC's proposed Astoria Replacement Project. The comments urged the DEC to deny the permit for the proposed Project because of its inconsistency with New York State climate and emission reduction goals set forth in the 2019 Climate Leadership and Community Protection Act (CLCPA).
AEC's comments address Astoria Gas Turbine Power LLC's incorrect claims that the proposed Project is CLCPA-consistent and that a hypothetical future conversion to hydrogen fuel is zero emissions or CLCPA-consistent. AEC's comments also outline the negative environmental justice and public health implications of hydrogen fuel use. We conclude that—with or without switching from gas fuel to hydrogen—the proposed Project is not consistent with the CLCPA.