Main Office: 33 Central Ave, 3rd Floor, Albany, New York 12210
Phone: (518) 462-5527  Fax: (518) 465-8349  E-mail: cectoxic@igc.org
www.cectoxic.org
April 21, 2014
2014 Draft State Energy Plan Comments
Energy Planning Board
NYSERDA
17 Columbia Circle
Albany, NY 12203-6399
Re: Comments on the Draft Energy Plan related to Sustainable Energy Options
The Draft Energy Plan appears to be a major effort to deceive the public. Volume 1 crows about
New York's initiatives to support sustainable energy options and a Clean Energy Future.
Unfortunately this enthusiastic support is not borne out in Volume 2 of the Plan, where the status
of existing goals is not adequately discussed and future goals for sustainable energy are not
advanced. A "Clean Energy Future" should have a definition that does not include expanded use
of fossil fuels or nuclear energy.
Unfortunately, the Potential Study for Energy Efficiency and Renewables has not been
forthcoming to the public despite multiple requests including a FOIL request. Yet enough work
had been done on this study for NYSERDA to present it at an Energy Planning Board meeting in
the Spring of 2012. The modeling showed that an additional 41% of our energy needs could be
met by energy efficiency and an additional 36% could be met by renewables-- adding to 77% of
our energy needs. By not providing this study and not discussing the results it would appear that
the state is serving the needs of major private sector participants involved with energy
production.
We provide detailed recommendations here with some supporting studies, related to energy
efficiency, renewables and waste policy.
“Best First” Policy options: Prioritize Sustainable options as "Best First"
A "Best First" Policy would prioritize the implementation of the most sustainable energy options,
those that provide significant benefits for New Yorkers. Given the economic crisis and NY's
budget deficit, this means those policy options that are low cost, create jobs and provide social
and environmental benefits. Without sustainability as a criterion, the "clean energy economy",
which remained undefined in the Draft Energy Plan could be nothing more than a cruel hoax.
A Clean Environment* Green Purchasing* Pollution Prevention* Healthy People* Green Jobs* Zero Waste
A Healthy Economy* A Sustainable Future
In a National Review of the Cost of Utility Energy Efficiency Programs report by the American
Council for an Energy Efficient Economy, March 2014, that looked in detail at state programs
across the US, energy efficiency was found to cost one- half to one- third the cost of new
electricity resource options at an average of 2.8 cents per kWh. Energy Efficiency is the Best
Value for consumers. Report attached to this submission
 The NY Draft Plan in just a footnote says: the NY ISO has estimated that based on
assuming current funding levels for Energy efficiency only 64% of the program
administrator goal (per 2008 PSC order) for energy efficiency will be achieved by 2015
and 93% will be achieved by 2022. However, a 2012 Synapse report addressing the
retirement of Indian Point, tells us that NY has achieved just 5370 GWh of the 24,900
GWh goal for 15% EE by 2015, or 21% of the goal. Synapse further estimates that
programs will have to be increased dramatically to reach the goal, but will likely not be
reached for some years after 2022.
 At the same time no new goals are advanced for energy efficiency going forward.
We recommend a dramatic expansion of Energy efficiency to achieve 15% by 2016 and
1.5% every year thereafter. By 2030 we would have reduced our baseline electric
generation by 36% to 104742 GWh through energy efficiency.
In June 2012 the National Renewable Energy Laboratory released a study finding that renewable
energy can meet 80 percent of U.S. power demand with existing commercial technologies, even
with variable resources like wind and solar. http://www.nrel.gov/analysis/re_futures/
 New York is failing to meet our renewable energy goals of 30% by 2015. The status of
the program is well hidden in the Draft Plan. According to the Synapse Energy
Economics report (2012) just 24% was generated from renewable resources in 2011.
We should update and expand the RPS, achieve the 30% goal by 2016 and then an
additional 1% per year into the future. This would mean 44% by 2030 and 64% by 2050.
In this way two thirds of our energy would be supplied by renewable resources. (Used 2012
GWh of 163,659 as baseline).
By 2030 we would have reduced our baseline electric generation by 36% to 104742 GWh
through energy efficiency. Then including the 44% of generation from renewables we would
need only 32732 GWh from other sources. In fact more may not be needed because distributed
generation and storage technologies would reduce transmission losses and problems associated
with variability.
Last week amid the dire warnings about the severity of the climate crisis, the UN Panel on
climate (IPCC) also had some good news: Renewables, not more nuclear reactors can solve the
climate crisis.
One of the key policies that was supposedly already implemented in the state, was the
2
decoupling of revenues and profits from state efforts to increase energy efficiency and
renewables. Unfortunately, this poorly defined plan does not appear to have produced any
results, since we learned absolutely nothing about measurable progress in the Draft Plan.
Renewables and energy efficiency are "BEST FIRST: policy options that will also help us reach
our official state climate policy goal of 80% reductions in total greenhouse gas emissions by
2050 from 1990 levels. However there is a notable problem with biomass as a renewable source.
The standards and criteria for the combustion of biomass has not adequately considered whether
biomass is from a sustainably operated resource and that replacement and growth exceeds what
is combusted. This issue has not been resolved to date. We were pleased to see that NY is not
planning for an increase in electric generation from biomass. New York's forests should be
primarily used for existing wood products industry and home heating. Consumers have been hit
hard by energy prices and further impacting home heating by decreasing supply is not in the
interest of consumers. We recommend no further approvals for biomass combustion plants as
renewable resources.
The oft-cited Jacobson, et.al. report tells us we can achieve 100% of our energy supply with
efficiency and renewable energy by 2030. These options also promise to do so while keeping
consumer costs low and dramatically reducing air emissions and thus public health impacts. It
should be noted somewhere in the comments on the Energy Plan that New York State has a great
deal of the intellectual capital on energy matters with Professor Howarth the first researcher to
quantify the extent of methane emissions associated with gas drilling, one of the authors of this
report along with Anthony Ingraffea, another expert. Sandra Steingraber is also a national expert
in toxic chemicals, endocrine disruption and the precautionary principle. We have the expertise
in New York to forge a more promising future.
Addressing Waste in NY offers also provides "Best First" options that save energy, water
use and resources. Unfortunately, waste is too frequently viewed as a way to generate
energy rather than how it should be viewed-- as a way to save a tremendous amount of
energy.
A huge amount of energy goes into extracting and processing resources, making them into
products and transporting them to consumers. Then the materials and the energy to produce them
are often wasted by disposing of them. These materials are often combusted in incinerators or
other thermal processes, destroying the materials to produce a small amount of energy. Waste is
in every aspect of our economy. In fact for every bag of garbage put at the curb by households,
70 bags of waste were produced upstream in processing.
Two recent reports examined the greenhouse gas impacts of products and packaging, the first
from EPA found 37% of GHGs associated with the production and delivery of non-food products
and packaging in the US. The second report, completed by the same author involved with the
EPA study was a follow-up and included global trade, although food was still not included; it
found 44% of GHGs associated with products and packaging. (Joshua Stolaroff, PhD worked on
the EPA report and subsequently extended the analysis to include products produced abroad and
consumed in the US. Both reports can be accessed at www.productpolicy.org )
3
The NYS DEC produced a "Beyond Waste Plan" for NYS in 2010, that recognized the multiple
energy and climate benefits of pursuing more sustainable methods of dealing with waste.
Unfortunately the economic crisis and reduced budgets meant that the programs needed were not
delivered. An economic study of the businesses and jobs associated with the reuse, recycling
and remanufacturing was completed in 2009 by the Northeast Recycling Council. it found there
were 3,948 businesses; 32,240 employees; $1.39 billion in payroll; $10.1 billion in total receipts
associated with this sector. DEC estimated the creation of 62,000 new jobs if there was a major
expansion of the programs in the "Beyond Waste Plan".
What the federal government, states and businesses around the country have learned is that
Waste= Inefficiency. This inefficiency wastes energy, water and resources. Major corporations
have set zero waste or waste free goals to transform their industrial processes and obtain millions
of dollars in savings. Zero Waste means zero waste sent for disposal. EPA has been involved in
major efforts for at least a decade. EPA has advanced sound waste policy as a tool to address
Climate Change. EPA's WARM modeling quantifies the major greenhouse gas benefits of waste
reduction, recycling and composting. Landfilling and incinerators contribute to climate change.
The IPCC has found that methane recovery systems only capture about 20% of landfill gas over
their landfill lifetimes. Incinerators produce only about 1/4 the energy that recycling saves, while
emitting a number of air pollutants including GHGs. Composting is the recycling of organic
wastes. Compost provides major climate change benefits including reducing the need for
artificial fossil fuel fertilizers, increasing the organic carbon in soils, improving soil water
retention and reducing plant diseases. Currently EPA is attempting to improve its analysis of
composting because their current model does not capture all of the GHG benefits associated with
composting. EPA's WasteWise Partnership program works with local governments and
businesses to share progress and success stories.
The Energy Hierarchy of Best First prioritizes Energy Conservation and Efficiency, which in the
Waste Hierarchy closely resembles Waste reduction or prevention. Renewable energy is closely
matched to reuse, recycling and composting as well as remanufacturing.
Citizens Energy & Climate Board
We believe it is long past time to permanently install New York Citizens on a fully funded board
to represent the public interest on all related energy matters as well as planning for community
adaptation and resilience in the face of Climate Change.
Recent news is very good for New Yorkers. The question is will the Final Energy Plan adopt the
best options with the fewest impacts or will the state act to increase the proportion of dirty and
unsafe energy. We have attached a number of relevant articles and brief reviews of recent
studies, as well as two factsheets related to waste.
Thank you for your attention.
4
Respectfully,
Barbara Warren
Executive Director
Citizens' Environmental Coalition
Stanford researcher maps out an alternative energy future for New York
A study, co-authored by Stanford researcher Mark Z. Jacobson, outlines a path to statewide
renewable energy conversion, and away from natural gas and imported fuel.
BY ROB JORDAN
Stanford Report, March 12, 2013
NYSERDA
Wind turbines on the Tug Hill plateau in upstate New York. A new study, co-authored by Stanford researcher
Mark Z. Jacobson, details how to convert New York's energy infrastructure to one powered by wind, water and
sunlight.
New York Gov. Andrew Cuomo will soon decide whether to approve hydraulic fracturing for
natural gas in the state. To date, no alternative to expanded gas drilling has been proposed.
But a new study finds that it is technically and economically feasible to convert New York's a llpurpose energy infrastructure to one powered by wind, water and sunlight (WWS). The plan,
scheduled for publication in the journal Energy Policy, shows the way to a sustainable, inexpensive
and reliable energy supply that creates local jobs and saves the state billions of dollars in pollution related costs.
5
Mark Z. Jacobson, a senior fellow with the Stanford Woods Institute for the Environment and the
Precourt Institute for Energy, co-authored the study with scientists from Cornell University and the
University of California-Davis.
"Converting to wind, water and sunlight is feasible, will stabilize costs of energy and will produce
jobs while reducing health and climate damage," said Jacobson, a professor of civil and
environmental engineering.
The study is the first to develop a plan to fulfill all of a state's transportation, electric power,
industry, and heating and cooling energy needs with renewable energy, and to calculate the number
of new devices and jobs created, amount of land and ocean areas required, and policies needed for
such an infrastructure change. It also provides new calculations of air pollution mortality and
morbidity impacts and costs based on multiple years of air quality data.
The study concludes that while a WWS conversion may result in initial capital cost increases, such
as the cost of building renewable energy power plants, these costs would be more than made up for
over time by the elimination of fuel costs. The overall switch would reduce New York's end-use
power demand by about 37 percent and stabilize energy prices, since fuel costs would be zero,
according to the study. It would also create a net gain in manufacturing, installation and technology
jobs because nearly all the state's energy would be produced within the state.
According to the researchers' calculations, New York's 2030 power demand for all sectors
(electricity, transportation, heating/cooling, industry) could be met by:

4,020 onshore 5-megawatt wind turbines

12,770 offshore 5-megawatt wind turbines

387 100-megawatt concentrated solar plants

828 50-megawatt photovoltaic power plants

5 million 5-kilowatt residential rooftop photovoltaic systems

500,000 100-kilowatt commercial/government rooftop photovoltaic systems

36 100-megawatt geothermal plants

1,910 0.75-megawatt wave devices

2,600 1-megawatt tidal turbines

7 1,300-megawatt hydroelectric power plants, of which most exist
According to the study, if New York switched to WWS, air pollution–related deaths would decline
by about 4,000 annually and the state would save about $33 billion – 3 percent of the state's gross
domestic product – in related health costs every year. That savings alone would pay for the new
power infrastructure needed within about 17 years, or about 10 years if annual electricity sales are
accounted for. The study also estimates that resultant emissions decreases would reduce 2050 U.S.
climate change costs – such as coastal erosion and extreme weather damage – by about $3.2 billion
per year.
6
Currently, almost all of New York's energy comes from imported oil, coal and gas. Under the plan
that Jacobson and his fellow researchers advance, 40 percent of the state's energy would come from
local wind power, 38 percent from local solar and the remainder from a combination of
hydroelectric, geothermal, tidal and wave energy.
All vehicles would run on battery-electric power and/or hydrogen fuel cells. Electricity-powered
air- and ground-source heat pumps, geothermal heat pumps, heat exchangers and backup electric
resistance heaters would replace natural gas and oil for home heating and air-conditioning. Airand ground-source heat pump water heaters powered by electricity and solar hot water preheaters
would provide hot water for homes. High temperatures for industrial processes would be obtained
with electricity and hydrogen combustion.
"We must be ambitious if we want to promote energy independence and curb global warming,"
said study co-author Robert Howarth, a Cornell University professor of ecology and environmental
biology. "The economics of this plan make sense," said Anthony Ingraffea, a Cornell engineering
professor and a co-author of the study. "Now it is up to the political sphere."
To ensure grid reliability, the plan outlines several methods to match renewable energy supply with
demand and to smooth out the variability of WWS resources. These include a grid management
system to shift times of demand to better match with timing of power supply, and "over-sizing"
peak generation capacity to minimize times when available power is less than demand.
The study's authors are developing similar plans for other states, including California and
Washington. They took no funding from any interest group, company or government agency for
this study.
. http://solartopia.org/un-panel-renewables-not-nukes-can-solve-climate-crisis
UN Panel: Renewables, Not Nukes, Can Solve Climate Crisis
APRIL 17, 2014 / HARVEY WASSERMAN /
http://progressive.org/content/un-panel-renewables-not-nukes-can-solve-climate-crisis
The authoritative Intergovernmental Panel on Climate Change has left zero doubt that we
humans are wrecking our climate.
It also effectively says the problem can be solved, and that renewable energy is the way to do it,
and that nuclear power is not.
The United Nations’ IPCC is the world’s most respected authority on climate.
This IPCC report was four years in the making. It embraces several hundred climate scientists
and more than a thousand computerized scenarios of what might be happening to global weather
patterns.
7
The panel’s work has definitively discredited the corporate contention that human-made carbon
emissions are not affecting climate change. To avoid total catastrophe, says the IPCC, we must
reduce the industrial spew of global warming gasses by 40-70 percent of 2010 levels.
Though the warning is dire, the report offers three pieces of good news.
First, we have about 15 years to slash these emissions.
Second, renewable technologies are available to do the job.
And third, the cost is manageable.
Though 2030 might seem a tight deadline for a definitive transition to Solartopia, green power
technologies have become far simpler and quicker to install than their competitors, especially
atomic reactors. They are also far cheaper, and we have the capital to do it.
The fossil fuel industry has long scorned the idea that its emissions are disrupting our Earth’s
weather.
The oil companies and atomic reactor backers have dismissed the ability of renewables to
provide humankind’s energy needs.
But the IPCC confirms that green technologies, including efficiency and conservation, can in fact
handle the job—at a manageable price.
“It doesn’t cost the world to save the planet,” says Professor Ottmar Edenhofer, an economist
who led the IPCC team.
The IPCC report cites nuclear power as a possible means of lowering industrial carbon
emissions. But it also underscores considerable barriers involving finance and public opposition.
Joined with widespread concerns about ecological impacts, length of implementation, production
uncertainties and unsolved waste issues, the report’s positive emphasis on renewables virtually
guarantees nuclear’s irrelevance.
Some climate scientists have recently advocated atomic energy as a solution to global warming.
But their most prominent spokesman, Dr. James Hansen, also expresses serious doubts about the
current generation of reactors, including Fukushima, which he calls “that old technology.”
Instead Hansen advocates a new generation of reactors.
But the designs are untested, with implementation schedules stretching out for decades.
Financing is a major obstacle as is waste disposal and widespread public opposition, now certain
to escalate with the IPCC’s confirmation that renewables can provide the power so much cheaper
and faster.
With its 15-year deadline for massive carbon reductions the IPCC has effectively timed out any
chance a new generation of reactors could help.
8
And with its clear endorsement of green power as a tangible, doable, affordable solution for the
climate crisis, the pro-nuke case has clearly suffered a multiple meltdown.
With green power, says IPCC co-chair Jim Skea, a British professor, a renewable solution is at
hand. “It’s actually affordable to do it and people are not going to have to sacrifice their
aspirations about improved standards of living.”
WIND
The Earth Policy Institute recently announced that World Wind Power is Poised to Bounce Back
after Slowing in 2013, principally due to a reduction in growth of wind in the US. See
www.earth-policy.org/indicators/C49/wind_power_2014
"At the end of 2013, the wind farms installed in more than 85 countries had a combined
generating capacity of 318,000 megawatts, which would be enough to meet the residential
electricity needs of the European Union’s 506 million people."
"Warren Buffett’s Mid American Energy Company purchased Siemens turbines totaling more
than 1,000 megawatts, all destined for Iowa wind projects."
"Denmark gets one third of its electricity from wind, well on its way to a target of 50 percent by
2020."
"Wind further solidified its role as the number three electricity source in China (behind coal and
hydropower), out-generating nuclear power by an impressive 22 percent."
PJM's integration study of Wind had the most significant findings. PJM is the largest grid
operator in the world and serves 60 million customers across 13 Mid-Atlantic and Great Lakes
states. In general wind is great for consumers -- reducing electric production costs, air pollution
and greenhouse gas emissions significantly. Reserves needed for variability were less needed
than previously thought and less than reserves needed for abrupt failures of conventional power
plants.
http://aweablog.org/blog/post/independent-grid-operator-30-percent-wind-drastically-reducespollution-and-costs-is-reliable See link for full article. Selected quotes below.
"Obtaining 20 percent of PJM’s electricity from wind energy reduces the cost of producing electricity by
about $10 billion annually (about 25 percent of total annual production costs of $40 billion), while 30
percent wind reduces production costs by about $15 billion (about 37.5 percent of total production costs)
each year.
Wholesale electricity prices are reduced by about $9–22 billion annually across the 20 percent and 30
percent scenarios, with the high offshore scenarios producing the largest wholesale price reductions of
$22 billion. This occurs because offshore wind tends to produce more during times of peak electricity
demand, offsetting more expensive gas generation.
Transmission costs were also found to be a very low $3/MWh in almost all cases, accounting for only
9
about 5% of the value provided by wind energy. The transmission costs were significantly lower than in
the study’s preliminary results. Importantly, other studies by independent grid operators have confirmed
that most transmission upgrades more than pay for themselves by providing other benefits, such as
improved electric reliability, reduced electricity prices, more competitive electricity markets, and
higher efficiency of electricity transmission relative to today’s congested electric grid.
Carbon dioxide emissions declined by 27–41 percent in the 30 percent renewable cases, and SO2 and
NOx emissions declined by 35% in the 30 percent wind case that deployed the best onshore wind
resources. Depending on the scenario, the wind cases reduced total PJM coal generation by 22–66
percent, with total PJM gas generation declining by 26–57 percent.
(C)hanges in wind energy output are reliably accommodated using the same tools grid operators
have always used to accommodate fluctuations in electricity demand as well as abrupt failures at
conventional power plants.
Building on NREL’s comprehensive analysis from last fall, this study puts further nails in the coffin of
the fossil fuel industry myth that wind energy’s emissions savings are less than expected because it
causes fossil-fired power plants to cycle more. A key reason is that wind energy’s gradual changes in
output are a small contributor to total power system variability, smaller than the variations in
electricity demand and the abrupt failures of conventional power plants.
For example, today’s study found that increasing PJM wind energy use by 7-fold by adding 28,000 MW
of wind would only increase the need for regulation reserves by 340 MW, or an extremely small increase
of about 1.2 MW of reserves for every 100 MW of added wind capacity. For comparison, PJM currently
holds 3,350 MW of expensive, fast-acting contingency reserves 24/7 to ensure that it can keep the lights
on in case a large fossil or nuclear power plant unexpectedly breaks down.
In other words, the total reserve need and integration cost for accommodating large fossil and
nuclear power plants (3,350 MW) is about 10 times larger than the incremental reserve need
associated with increasing PJM wind use by 7-fold (340 MW). As further testament to the fact that
wind energy is a small contributor to total power system variability, PJM’s study found that the total
cost of cycling all power plants dropped from $870 million in the base scenario to $500 million in
the scenario with 30% wind energy.
The study found that cycling’s impact on smog-forming SO2 and NOx emissions was in the single digit
percents across all scenarios, i.e. wind produced more than 90% of the expected emissions reductions
for these pollutants. As explained above, carbon dioxide emissions declined by 27–41 percent in the 30
percent renewable cases, consistent with NREL’s finding that the impact of wind-related cycling on CO2
emissions is “negligible.” Specifically, NREL’s analysis found that cycling reduced wind’s carbon
dioxide savings by 2.4 pounds per MWh, or 0.2% out of wind’s total emissions savings of 1,190 pounds
per MWh, so wind produced 99.8% of the expected carbon emissions reductions.
PJM’s study further reinforces other studies that have found wind energy is a win-win-win for
consumers, the environment, and electric reliability.
For example, a May 2013 analysis by Synapse Energy Economics found that doubling the use of wind
energy beyond existing standards in PJM would reduce carbon pollution by 50 million tons per
year and maintain reliability while saving consumers $6.9 billion per year on net, after accounting for
all wind and transmission costs. In numerous cold snaps over the last two months, including several in
PJM, wind energy has proved its reliability and value by providing large amounts of valuable energy
when grid operators needed it most, protecting consumers by keeping electricity and natural gas price
spikes in check."
Tidal & Wave Energy
10
THINK PROGRESS
/
http://thinkprogress.org/climate/2014/03/26/3416261/oceans-power-future
Blue Is The New Green: How Oceans Could Power The Future
BY ARI PHILLIPS
ON MARCH 26, 2014 AT 11:42 AM
In February, a natural gas power plant along the Central California coast closed after operating for more
than 50 years, thus ending an era that saw the surrounding community of Morro Bay grow up around it. In
an unlikely partnership, the shuttering may also help usher in a new era of energy generation — this one
reliant on power from the waves that undulate through the bay before crashing up against the nearby
shoreline.
The antiquated Morro Bay plant is part of a pattern of seaside plants closing due to a combination of
stricter environmental regulations coupled with California’s requirement that 33 percent of electricity in
the state come from renewable sources by 2020. Two companies have filed preliminary permits with the
Federal Energy Regulatory Commission (FERC) to test wave energy projects off the coast of Morro Bay,
a town of about 10,000 people north of Los Angeles. Both projects would use the defunct plant as a
much-needed transmission hub to push energy to the grid and from there to consumers throughout the
region.
“If we aren’t able to use Morro Bay, there are other shore-based power plants shutting down along the
coastline,” said Paul Grist, president and chairman of Archon Energy, one of the companies applying for
a FERC permit. “They can’t meet the Renewable Portfolio Standard and they suck in and spew out
millions of gallons of water.”
Dynegy, the owner of the power plant, is the other company that applied for a FERC permit. A Houstonbased utility company with around 13,000 megawatts (MW) of nationwide power generation capacity,
their February 6 application with FERC came several months after Archon’s. If their project tests
successfully and goes on to get the two dozen or so licenses and permits that would be needed, it would
eventually generate 650 MW of power and cost more than $1 billion to build.
“Dynegy filed their permit many months after we did,” Grist said. “Our goal was to use that transmission
corridor to the coast and Dynegy basically followed. Their application is further towards land than ours.
I’ve talked with them and we’re going to try to work together and help each other out as much as we can.”
Wave energy will be coming of age in the immediate future.
Archon Energy, co-founded by Grist in 1999 when he was 20 years old, is a small, independent power
producer focusing on next generation technologies with minimal environmental impacts. In the fall of
2013, the company filed for a FERC permit to pursue testing on a one-by-fifteen mile site several miles
offshore that would cost about $1 million. Grist said they are waiting for preliminary permits to start
investing significant capital and holding consultations with stakeholders, including local community
members and environmental groups. However, he’s had his eye on hydrokinetics — the production of
energy from the flow of moving water — for a decade.
“There’s a lot of technology happening in wave energy conversion,” Grist said. “Wave energy will be
coming of age in the immediate future.”
11
A gray whale swims past the Morro Bay Power Plant. CREDIT: Michael L. Baird,
flickr.bairdphotos.com
Ocean-Powered Future
A spate of recent developments would seem to support Grist’s prediction. In March, Lockheed Martin, a
global defense, security and technology company, signed on to help build what will be the world’s largest
wave energy project — a 62.5 MW project several miles off Australia’s southern coast that will have the
capacity to power 10,000 homes. Across several oceans, a 320 MW tidal project, another world’s largest,
is under consideration off the coast of Wales. Ideally, it will lay the groundwork for similar installations
around the U.K.
The first FERC-licensed, grid-connected tidal project was approved in 2012 off the coast of Maine for the
Portland-based Ocean Renewable Power Company. Having invested over $20 million dollars in the
project, no major negative environmental impacts have been observed thus far and the company plans to
expand the installation this year, deploying several additional devices and greatly increasing the amount
of tidal power they are capturing.
On March 20, in an indication of FERC’s willingness to support such technologies, the agency approved
a ten-year pilot license for the 600 KW Admiralty Inlet Pilot Tidal Project to be located in Puget Sound
off Washington state. The project will be grid-connected and, as the first U.S. undertaking at such a scale,
is leading an effort to better understand how wave and tidal energy projects interact with local
environments, numerous stakeholders ranging from tribal groups to business organizations, and the
electric grid.
“Anyone who has spent time on the waters of Puget Sound understands the power inherent in the tides,”
Steve Klein, Snohomish Public Utility District (PUD) General Manager, told the local news. “In granting
this license, the FERC acknowledges the vigilant efforts of the PUD and its partners to test the viability of
a new reliable source of clean energy while at the same time ensuring the protection of the environment
and existing uses.”
Ocean current resources are about 800 times denser than wind currents … meaning a 12-mph marine
current generates the equivalent amount of force as a 110-mph wind gust.
Wave and tidal power are both hydrokinetic sources of energy. Wave power harnesses the energy of
surface waves through a number of different mechanisms, many still in early stages of development.
Currently the primary method involves floating buoys the size of lighthouses that are moored to the ocean
floor. In another example, a group of researchers at UC-Berkeley have developed what they call a
“seafloor carpet” that absorbs the impact of ocean waves much as muddy seabeds do.
Tidal power uses the flow of ocean currents, tides or inland waterways to capture the potential energy
between high and low tides as they occur every 12 hours. “The rotation of the earth creates wind on the
12
ocean surface that forms waves, while the gravitational pull of the moon creates coastal tides and
currents,” the National Renewable Energy Laboratory (NREL) explains.
Ocean Power Technologies’ PowerBuoy uses a buoy to convert wave energy into electricity.
CREDIT: Ocean Power Technologies, Inc.
As the search for new forms of clean, sustainable energy persists, the global potential of wave and tidal
power represents an untested but immensely promising frontier. Oceans cover 70 percent of the Earth’s
surface — and they do so densely. Ocean current resources are about 800 times denser than wind
currents, according to NREL, meaning a 12-mph marine current generates the equivalent amount of force
as a 110-mph wind gust. With more than half of all Americans living near the coastline, wave and tidal
power is also appealing for its proximity to electricity demand centers, whereas the many of the best wind
and solar sites are hundreds of miles from population hubs.
A 2012 report prepared by RE Vision Consulting for the Department of Energy found that the theoretical
ocean wave energy resource potential in the U.S. is more than 50 percent of the annual domestic demand
of the entire country. The World Energy Council has estimated that approximately 2 terawatts — 2
million megawatts or double current world electricity production — could be produced from the oceans
via wave power.
Testing Waves Up And Down The Coast
But even in the small nook of ocean lapping into Morro Bay, an impressive amount of energy is being
devoted to the development of wave, and possibly tidal, power generation. Just about a dozen miles
inland from the Bay, research into setting up a National Wave Energy Test Facility in California
(CalWave) is underway at Cal Poly in San Luis Obispo. As part of the newly formed Institute for
Advanced Technology and Public Policy, the facility has been selected by DOE to determine which
location along California’s coast has the best potential to accelerate the development of a commercial
ocean renewable energy industry. IATPP, formed in 2012, is the brainchild of former California State
Senator Sam Blakeslee, who has been running it since its inception on a pro-bono basis. Blakeslee has a
Ph.D. in geophysics from nearby UC-Santa Barbara and also worked as a strategic planner for Exxon
before entering state politics in 2005. He left politics just over a year ago after leading the GOP State
Assembly and helping craft California’s Renewable Portfolio Standard, among other things.
13
“I have no plans to return to politics,” Blakeslee told ThinkProgress. “The best place to drive policy right
now is in some of these think tanks working on exciting new ideas, and not in state houses or on the Hill
where people can’t seem to agree on anything.”
Blakeslee wants to help develop and spread the potential transformative benefits of emerging
technologies rather than get bogged down by laws, regulations, and standards that can actually impede the
application of such innovations. And after signaling its interest in giving up to $40 million to the
expansion of wave energy technologies — pending Congressional approval — its seems DOE is pursuing
the same type of paradigm-shifting innovation.
Blakeslee likens the prospect of a national wave testing facility to the public-private partnership that led
to the proliferation of satellites. In that case, satellite owners and operators share in the common
technology and infrastructure provided by the government which would otherwise be cost-prohibitive to
development.
“The Obama administration is looking to develop the test facility so companies can test equipment and
compare results in a facility that would otherwise be unavailable to them individually,” Blakeslee said.
“Down the road as the technology develops there will be wave farms, and this is one of the major steps
towards that. By having this facility in the U.S. the likelihood that the country will be a big commercial
player in the industry greatly increases.”
By having this facility in the U.S. the likelihood that the country will be a big commercial player in the
industry greatly increases.
Blakeslee has had conversations with Grist about the type of research that needs to occur off Morro Bay
before any siting decisions are made. He and Grist both expressed concern for marine life, especially
migratory mammals such as blue whales, gray whales, and humpback whales, as well as fishing
communities that could be impacted by the projects. These concerns will need to be addressed up and
down California’s 750-mile coastline and the rest of the West Coast if wave and tidal power are to
proliferate.
The closing of the Morro Bay Power Plant is not a one-time, serendipitous occasion, but part of a trend of
coastal power facilities closing due to old age and new regulations aimed at protecting sea life being
negatively impacted by the facilities’ cooling systems. In fact, the plant is just one of 19 gas-fired power
plants along the coast of California to be phased out of operation in order to project marine life from
being sucked through their cooling systems or impacted by the hot water released back into the ocean.
This will open up 5,500 MW of transmission lines and a similar amount of energy demand — although
many would like to see some of that demand reduced through efficiency and conservation measures rather
than replaced, even by sustainable sources.
Farther down the coast, the recent closure of the San Onofre Nuclear Generating Station has opened up
not only hundreds of megawatts of transmission lines, but also a power supply void that will need to be
filled. The California Public Utilities Commission recently directed Southern California Edison and San
Diego Gas & Electric to secure up to 1,500 MW of new energy by 2022, with at least 600 MW coming
from renewable energy sources or energy efficiency measures.
Having available transmission lines is critical for a nascent technology like wave power. “Building
transmission lines in California can take up to a decade,” Blakeslee said. “The availability of transmission
lines and to have a prescribed amount of power brought into the system through Independent System
Operators are big considerations for any energy project in the state.”
Overcoming The Barriers
14
Transmission is far from the only challenge wave and tidal power will have to overcome on the path to
becoming major energy providers. New Jersey-based Ocean Power Technologies encapsulates the upsand-downs of the early days of the industry. In February, Ocean Power Technologies signed on to provide
buoys for the Lockheed Martin project off the coast of Australia, a major deal that sent the company’s
stock soaring. The company has spent millions of dollars developing a PowerBuoy that converts ocean
wave energy into commercial scale electricity. Standing 140 feet tall, it resembles a giant metal detector
and when submerged in the ocean, only the handle remains above water. The tip-of-the-iceberg effect in
the form of wave energy.
Then in March, Ocean Power Technologies shelved its much-hyped plans to develop the country’s first
large-scale wave energy project off the coast of Oregon, which would have employed a flotilla of up to
100 buoys.
Ocean Power Technologies’ PowerBuoy wave generation system.
CREDIT: Youtube Screenshot
A key challenge is that all new technologies are initially uncompetitive.
Kevin Watkins, the Pacific Northwest representative for Ocean Power Technologies, told the Oregonian
that implementing the wave energy technology on a large scale became too expensive and complicated.
The cumbersome regulatory process and concern from fishing and crabbing communities about ecological
and economic impacts caused unanticipated delays.
Peter Fraenkel, co-founder of U.K.-based Marine Current Turbines Limited and a pioneer in the field of
wave and tidal energy, thinks that the bottom-line concern is really cost.
“A key challenge is that all new technologies are initially uncompetitive,” he told ThinkProgress via
email. “Conventional generation using steam turbines, gas turbines or nuclear for example were originally
developed on an almost cost-no-object basis mainly for military purposes. Sadly there seems to be no
military application for wave or tidal energy so it will need subsidies in some shape or form for early
projects.”
15
Fraenkel also acknowledges the challenges of grid connectivity, saying that in the U.K., unlike along
California’s coastline, promising tidal and wave resources lack easy transmission options. “So we have a
‘Catch 22′ situation where nobody wants to invest in grid extension until the technology to generate into
the grid extension is ready and nobody wants to invest in projects where there is no certainty of having a
grid connection.”
While oceans may cover more than two-thirds of the planet, wave and tidal power require concentrated
energy locations with strong currents or consistently large waves. This limits the opportunities to a tiny
percentage of the ocean, according to Fraenkel. So on top of technological advances and economic
favorability, siting, natural resources availability, and transmission access must all align for a successful
wave or tidal power project. Even so, Fraenkel views the challenges as not only worth overcoming, but
necessary to overcome.
“The oceans contain a huge amount of energy so logic dictates that we need to learn to extract energy
where possible bearing in mind that future use of fossil fuel is going to be inhibited both by the effects of
pollution induced climate change and by resource depletion,” he said. “So my message is that although
extracting energy from the oceans is more difficult and perhaps less successful so far than some people
might have wished, it has been shown to be possible and will no doubt become increasingly important in
future.”
Solar wins support over natural gas
While Tidal and Wave Energy are developing, solar and wind have shown exponential growth.
In Minnesota a judge ruled that the better economical deal for the state was solar rather than natural gas
generators. It is the first time that unsubsidized solar energy has gone head-to-head with natural gas
resources and been selected as the best option.
Major Solar Energy Plan for MN Wins Support Over Gas
January 3, 2014
Experts say decision marks turning point and believe 2014 will be ‘exciting year’ for solar power
by Amel Ahmed, Al Jazerra America, January 2, 2014
Read More: Massive Minnesota Solar Project Gets Major Legal Boost
"In an unprecedented decision, a Minnesota judge this week held that utility supplier Xcel Energy should
invest in the solar energy developer Geronimo Energy rather than in natural gas generators because that
choice is the better economical and environmental deal for the state.
Judge Eric Lipman’s ruling must be approved by the Minnesota Public Utilities Commission, which
initially ordered the proceeding to force energy companies to compete on price. The commission is
expected to issue its final ruling in March.
Lipman said in the 50-page ruling, issued Tuesday, that the Geronimo project “will have numerous
socioeconomic benefits, minimal impacts on the environment and best supports Minnesota’s efforts to
reduce greenhouse gases.”
The decision, if approved, would help Xcel fulfill its requirement to attain 1.5 percent of its power from
the sun by 2020 under a new state energy law.
Geronimo Vice President Betsy Engelking said the decision marks a turning point for the solar industry
16
because it is the first time that unsubsidized solar energy has gone head-to-head with natural gas resources
and been selected as the best option.
“The judge decided that it was the best option for economic and environment reasons,” Engelking told Al
Jazeera. “Economically, the judge found that it was the lowest cost option offered.”
If the decision stands, Geronimo plans to build roughly 20 solar arrays at a cost of $250 million.
Gov. Mark Dayton, a Democrat, approved an economic development bill last spring that included a solar
energy standard mandating that by 2020, 1.5 percent of the state’s electricity must be solar-generated.
Additionally, Minnesota’s Renewable Energy Standard requires utilities to provide 25 percent of their
total electrical generation from renewable sources by 2025.
The combustion of fossil fuels to generate electricity is the largest single source of carbon dioxide
emissions in the U.S., according to the Environmental Protection Agency. Greenhouse emissions such as
carbon dioxide are major contributors to global warming.
The United Nations Intergovernmental Panel on Climate Change (IPCC) estimates that up to 30 percent
of plant and animal species face extinction by midcentury if global warming is left unchecked.
Greenpeace spokesman David Pomerantz told Al Jazeera that solar energy “has always been better for our
environment” than burning fossil fuels like coal and gas. “Rulings like this one in Minnesota are proving
that it’s better for our pocketbooks too. Electric utilities around the country should embrace the solar
revolution that their customers are increasingly demanding, or they risk becoming fossils themselves.”
Engelking told Al Jazeera that she expects similar measures to be passed across the country, given that the
price of solar energy has come down to the point where it’s comparable to that of natural gas.
She attributes the reduction in solar energy costs to improved technology and fierce competition,
particularly from China, which has caused the price to come down “about five years faster than anyone
expected it to.”
A majority of states have what is known as Renewable Portfolio Standards (RPS), policies designed to
increase generation of electricity from renewable resources, according to the U.S. Energy Information
Administration (EIA). These policies require or encourage electricity producers to supply a certain
minimum share of their electricity from designated renewable resources.
There is currently no RPS program in place at the national level. However, 30 states and the District of
Columbia have enforceable renewable capacity policies as of January 2012, according to the EIA’s
website. "
Energy Storage: The Next Charge for Distributed Energy, John Farrell, March 2014 ,
Institute for Local Self- Reliance.
http://www.ilsr.org/energystoragethenextchargefordistributedenergy/
This 40 page report discusses how and why energy storage will be expanding.
Uses for energy storage include:
"• Managing Supply and Demand – energy customers can reduce their bills by shifting energy use to low
demand periods or by reducing their maximum energy use in a given month. Energy storage can cost
effectively supply capacity and backup power that has historically been provided by expensive quick
response fossil fuel power plants.
17
• Delivering Ancillary Services – at every moment supply and demand of electricity must be in balance.
Energy storage can respond more quickly than most existing technologies, helping maintain the voltage
and frequency of the electricity system to avoid damage to connected electronics and motors, and avoid
power outages.
• Reinforcing Infrastructure – power lines, transformers and other grid infrastructure wears more quickly
when operating at peak capacity. Energy storage can shift energy demand to ease stress on expensive
equipment. It also allows energy users to manage their own energy use.
• Supporting Renewable Energy – renewables are often variable, and variable energy can be
challenging for inflexible utility power plants to accommodate. Energy storage responds quickly
and effectively to variations in renewable energy output, enabling higher penetrations of wind
and solar on the electric grid."
Citizen's Environmental Coalition Factsheets
New Yorkers for Zero Waste Platform 2010
The N.Y.S. Department of Environmental Conservation (DEC) has prepared a new State Solid
Waste Plan that recognizes that materials in our waste stream are valuable and need to be
preserved. We strongly endorse its preference for waste reduction, reuse, recycling and composting
over disposal. The less waste we dispose of the more environmental, economic and social benefits
that we will enjoy.
Unfortunately, millions of tons of garbage are still being wasted through disposal in landfills or
incinerators. The DEC estimates New York’s recycling rate to be only 20%, far short of the 50%
reduction and recycling goal that was to be met by 1997 under the State Solid Waste Management
Act of 1988. A large portion of waste headed for disposal is recyclable (50%) or compostable (30%).
To achieve the goals of the Plan, we must stop trashing our resources through disposal!

Incinerators emit toxic air emissions and produce toxic incinerator ash that needs landfilling.
They also emit more CO2 than coal burning plants per MWh. Incinerators must have
burnable materials and therefore compete with recycling.

Recycling saves 4-5 times the energy an incinerator recovers.1 Incineration is not renewable
energy.
To address climate change we must address waste in our society!

For every trash bag we put at the curb, 70 bags of trash were generated by
industry to make the products we buy. The production of products and
packaging is associated with 44% of all greenhouse gas emissions.2

Biodegradable materials in landfills emit methane, a gas that has 72 times the
global warming potential of CO2, over a 20 year period.3 Landfill gas collection systems
capture only about 20% of landfill gas.4

The best strategy is to divert biodegradable organic material away from landfills and
incinerators to composting. Compost provides nutrients for healthy soils and plants.
18
Burning and burying garbage wastes money, energy, and natural resources; it
contributes to climate change and places an unfair pollution and health burden on
nearby communities. Diversion saves energy and resources, and creates many more
jobs in collection, processing, reuse of goods and remanufacturing of materials.
Maximizing waste reduction and diversion will dramatically decrease waste sent for
disposal over time by 70%, 80%, 90% and more, enabling New York to achieve the
significant benefits of a more sustainable system. The ultimate goal should be Zero
Waste being sent to Disposal or very close to it.
____________________________________________
1
EPA's WARM Model.
recent EPA report found that non-food products are associated with 37 percent of U.S. greenhouse gas
emissions. Joshuah Stolaroff, PhD worked on the EPA report and subsequently extended the analysis to include
products produced abroad and consumed in the US. This white paper states total GHG emissions of products and
packaging is 44%. Both reports can be accessed at www.productpolicy.org
3 IPCC, 4th Assessment Report.
4 Ibid., Working Group III, Mitigation, 10.4.2.
2A
We call on the Governor, the NYS DEC and the NY State Legislature to support a new,
sustainable direction for reducing waste, recovering resources and growing jobs as well
as obtaining other benefits for New Yorkers by doing the following:

Establish a moratorium on construction of all new waste incinerators or combustors as well
as expansions of existing incinerators. This would include newer, commercially unproven
thermal technologies such as gasification, pyrolysis and plasma arc.

Ban waste haulers and municipalities from sending recyclable materials for disposal, and
instead require recyclables to be source separated and transported to recycling processing
facilities.

Halt all increases in capacity at the state’s largest landfills.

Require all local solid waste planning units and haulers sending garbage for disposal to
demonstrate the presence of adequate programs of waste reduction, recycling and
composting in the service area.

Rapidly implement organics collection programs and develop the
needed composting and anaerobic digestion infrastructure. Ban yard
trimmings from disposal now and ensure the ban's enforcement.
Establish a statewide ban on the disposal of food scraps by 2013.

Require all communities to adopt incentive/disincentive programs,
such as Pay-As-You-Throw, which are proven to increase diversion
rates.

Adopt Extended Producer Responsibility (EPR) legislation (also
known as product stewardship) to engage manufacturers and
importers in the design of products and packaging to reduce waste and toxicity and remove
the burden from government and taxpayers. Producers of products and packaging must be
part of the solution. Ten to fifteen percent of the waste stream should be reduced through
EPR measures.
19

Regulate solid waste generated by all sectors – residential, commercial, institutional and
industrial. Bring waste haulers and transporters under the jurisdiction of the DEC through
licensing, requiring reporting of all waste and recyclable collections and disposal, and
providing for oversight and compliance.

Require local solid waste planning units to prepare implementation plans that increase waste
reduction and diversion and decrease disposal. State and local plans must decrease
disposal by 50% by 2015, and 85% by 2020 for all waste streams. The implementation
plans must be enforceable by DEC.

Ensure accurate measurements of diversion and waste quantities in order to measure
progress toward goals. Plan to reassess goals and progress and adjust programs under a
revised 2020 statewide plan.

Ensure that Zero Waste Programs and their greenhouse gas benefits become a substantial
part of the new state Climate Action Plan and its implementation.

Establish a secure funding stream to fund more sustainable solid waste programs over the
long term and achieve job benefits and needed greenhouse gas emission reductions.
Licensing fees, facility permit fees and surcharges on disposal should all be used to provide
dedicated funding. A surcharge of at least $20 per ton of MSW generated could provide $5
per ton to the state for solid waste activities and $15 to local planning units to support
needed recycling and composting facilities as well as educational programs.
To support this platform or for more information, contact: Barbara Warren, NY Zero Waste
Alliance, project of Citizens Environmental Coalition, warrenba@msn.com or 845-754-7951/
518-462-5527.
Organizational Supporters
Listed Below
New York Statewide Organizations
Atlantic States Legal Foundation
Citizens' Environmental Coalition
Clean New York
Hudson River Sloop Clearwater
Environmental Advocates of New York
New York Public Interest Research Group
Sierra Club Atlantic Chapter
Local and Regional Organizations
Adirondack Communities Advisory League
Capital District Branch of NY Apollo Alliance
Concerned Citizens of Seneca County, Inc.
Concerned Citizens of Cattauragus County
Concerned Residents of Portland, NY + People Like Us (Crop Plus)
Finger Lakes Citizen's for the Environment
Finger Lakes Zero Waste Coalition, Inc.
Freshwater Future
Greenwich Citizens Committee, Inc.
20
Jamesville Positive Action Committee
NYC Apollo Alliance
people's Environmental Network of NY
Residents For the Preservation of Lowman and Chemung (RFPLC, Inc)
Save the Pine Bush
Selkirk, Coeymans, Ravena Against Pollution
Sure We Can
Sustainable Flatbush
Sustainable South Bronx
The Solidarity Committee of the Capital District
Village Independent Democrats
Washington County Democratic Committee
National
American Environmental Health Studies Project
Center for Health, Environment & Justice
Institute for Local Self-Reliance
Reuse & Recycling GROWS JOBS Locally!
Factsheet
National Estimates
The Reuse and Recycling Industry has had sustained growth for over 30 years
nationally.
In 1967, there were 8,000 companies employing 79,000 people with sales of $4.6
billion.
As of 2000, the industry had grown to 56,000 public and private sector facilities with 1.1
million people and $236 billion in gross sales. A total growth of 1300%!
The growth in employment in this sector was 5 times the growth in total employment
nationwide.
The "Indirect" effects of this industry on supporting businesses were estimated to
provide an additional 1.4 million jobs and $173 billion in receipts.
(U.S. Recycling Economic Information Study, prepared by RW Beck for the National
Recycling Coalition, July 2001, available on the Web at:
http://www.epa.gov/waste/conserve/rrr/rmd/rei-rw/index.htm)
Waste Reduction, Reuse, Recycling and Composting offer the most direct economic
development tools available to local communities. Not only are resources and energy
saved in the process, but there are new jobs created in the process. Discarded
21
materials provide the local resource to increase local revenues, create jobs, and attract
new businesses to the ready supply of materials.
Simply the sorting and processing of recyclables provides 5 to 10 times more jobs than
landfilling or incineration. But Reuse and remanufacturing can provide many times
more jobs, between 28 and 296 jobs for each one in disposal. (Wasting and Recycling
in the US, 2000, Grassroots Recycling Network citing ILSR.)
Manufacturing from locally collected discards adds value by producing
finished goods. This picture is more sustainable economically and
environmentally that exporting raw materials and importing finished
goods.
According to the Institute for Local Self-Reliance, "Closing the loop
locally" -- by recovering more materials and developing local
remanufacturing, reuse, and composting businesses as markets for
these materials -- is the key to maximizing recycling-based economic
development.
Consider Philadelphia. This story is provided by the Institute for Local Self-Reliance
and available at www.grrn.org Since implementing curbside recycling, between 1986
and 1993, Philadelphia attracted 46 new recycling-related businesses interested in
locating in and around the city (with a potential to create 2,000 new jobs). Between
1993 and first of half of 1994 (latest figures available), eight new businesses were
established that created 81 jobs, and another 7 businesses, slated to create 284 jobs,
were considering locating or expanding in and around the city.
In New York State 2009 Data
Businesses and Jobs associated with the REUSE, RECYCLING AND
REMANUFACTURING INDUSTRY.
3,948 businesses
32,240 employees
$1.39 billion in payroll
$10.1 billion in total receipts
(Northeast Recycling Council Economic Study for the
Northeast, Sept. 2009).
The DEC estimates that the NEW State Solid Waste Plan
would create more than 62,000 new jobs as the result of
DEC's proposed major expansion of material recovery
efforts.
Not Yet Adequately Quantified
Jobs in some areas are not adequately quantified yet. Recycling educators and
outreach workers, those involved in oversight, and planning tasks, and those that utilize
compost materials in nursery businesses, farms and greenhouses are not regularly
included in job estimates. We do know however that the supply of compost runs out in
the early summer, while there is a demand for this valuable soil amendment for 3-4
more months.
22
Tons vs. Value
Solid Waste is most often measured in Tons. Yet when we purchase goods at a store,
we are paying in dollars. Remanufacturing sells products for dollars. Where this gets
tricky is in the REUSE arena. Too often former solid waste managers want to count
reusable goods as tons diverted rather than for value- added goods sold and the
benefits provided. The overall social benefits of reuse to schools, charitable
organizations and those on fixed incomes can be extraordinary. For Reuse operationsCount Value Not Tons!
Prepared for NY Zero Waste Alliance, managed by Citizens' Environmental Coalition, 33 Central
Ave. Albany, NY 12210, 518-462-5527. Contact Barbara Warren also at 845-754-7951 or
warrenba@msn.com
23