Tell the PSC: Reject National Grid's Long-Term Plan and the NESE Pipeline

Public comment regarding National Grid's long-term plan (Case 24-G-0248)

I am writing regarding National Grid's recent addendum to its long-term plan. While the Company attempts to use its latest filings to endorse a massive gas pipeline expansion -- the Northeast Supply Enhancement (NESE) -- the Company's filings reveal that there is no need for the pipeline, and that National Grid's Downstate customers would bear massive costs without receiving a commensurate benefit. More fundamentally, National Grid fails to meaningfully grapple with how NESE would impact its previously filed gas system long-term plan, which provided a plan to meet a higher demand forecast without the new pipeline. National Grid has not shown there is a need for a huge new gas pipeline to New York City. In its supplemental filings, the Company reveals that it recently updated its long-term demand forecast, revising it downward substantially. National Grid now projects that any supply shortfall, even absent the NESE project, would not occur this decade, but would occur at the earliest in the 2040's. Electrification trends, together with Local Law 154 and the State's All-Electric Buildings Act's limitations on gas in new construction, are all serving to reverse historic gas demand growth, and these trends are likely to accelerate in the future. Locking in a long-term contract for capacity on the NESE pipe presents a significant risk for National Grid's gas customers. As the Public Service Commission's independent consultant explained, "[w]ithout incremental design day demand, it is possible that the investment in NESE will be a stranded cost that National Grid's customers are responsible for." (PA Report on National Grid's Final Gas System Long-Term Plan Addendum at 22) In addition, National Grid's Downstate gas customers would underwrite NESE through long-term capacity contracts, but they would not be the primary beneficiaries of the pipeline. National Grid's supplemental filings show that, while the Company's gas customers would pay billions for gas pipeline capacity -- raising customers' gas bills by over $7/month -- the primary benefits of the pipeline would be to electric ratepayers throughout the state. Ultimately, NESE is out of step with the State's broader decarbonization efforts, which aim to reduce, not expand, gas consumption. Moreover, National Grid's consuming focus on NESE is a distraction from the flaws with the Company's final long-term plan, which is itself out of step with the State's vision for gas system transition set forth in the Climate Action Council's Scoping Plan and more recently in the draft State Energy Plan. I urge the Commission to reject National Grid's final gas plan.