CAYUGA OPERATING COMPANY, LLC

228 Cayuga Drive

Lansing, NY 14882
Telephone: (607) 533-7913
Fax: (607) 533-8744

Chair Anna Kelles

Planning, Development, and Environmental Quality Committee
Tompkins County Legislature
Tompkins Building
Ithaca, NY 14850

November 8, 2018
Dear Chair Kelles:
Thank you for your invitation to address draft resolutions being considered by the Planning,
Development, and Environmental Quality Committee involving the Cayuga Operating Company. We
regret that the timing of this invitation did not allow us to appear before your committee in person;
however, we thought it would be useful if we provided you and the committee our written feedback.

We believe the repowering of Cayuga with trucked natural gas in conjunction with a large scale
solar and energy storage development would be a worthy and beneficial project for Tompkins County
and the Southern Tier environmentally, economically, and for stated policy goals. Our confidence in
this regard is bolstered by the recent 2017 countywide poll of Tompkins County residents
commissioned by Cayuga and the New York State Building and Construction Trades Council that
showed a clear majority of county residents (64%) support Cayuga’s repowering plan.

Specifically, the redevelopment of Cayuga into an energy park powered by natural gas and solar
energy would provide the following advantages for New York State, Tompkins County and the
Southern Tier:
• achieves Governor Cuomo’s goal of closing coal plants in New York by 2020i
• reduces dramatically air emissions:
o SO2 (sulfur dioxide) – zero emissions
o NOx (nitrogen oxides) – 88% reduction
o CO2 (carbon dioxide) – 50% reduction
o Particulate matter – 98% reduction
• fulfills a recognized need for cleaner natural gas plants to bolster New York State’s proposed,
but highly variable, renewable energy grid
• preserves 36 union jobs at an average salary of $87,000
• maintains local PILOT payments to schools and local government, currently set at $927,000
per year
• creates significant local economic activity around new development and construction
o combined capital investment of an estimated $33-$35 million
o up to 230 construction jobs in the 2- 3-year time frame for repower and solar
development
 • address reliability concerns of regulators and NYISO more efficiently and cheaply than any
other option given the benefits of the existing interconnect, site control, available land, zoning
at Cayuga

Finally, the draft resolutions under consideration place significant emphasis on the issue of
truck safety. Indeed, Resolution B declares that CNG trucks used in a Cayuga repowering effort
would “creat[e] a danger to human health” through the Southern Tier and Tompkins County. All
CNG trailers are US DOT certified for over-the-road use and have superior safety devices compared
to the 40+ year-old oil and propane trailers that operate across Tompkins County and New York and
are exempted from state-of-the-art safety equipment. One of the carriers we have consulted, Xpress
Natural Gas (XNG), has the highest safety rating from the Federal Motor Carrier Safety
Administration; over the last five years, XNG reports it has had only six reportable incidents over the
course of 15,000,000 road miles.
Cayuga has extensively studied potential truck safety implications for the local roadways in
considering the repowering option via trucked gas, and we respectfully encourage the committee to
seek input from the transportation sector on the safety record of CNG tankers and more detail on the
circumstances relating to the incidents cited in the resolution, before including generalized language
that the CNG trucking industry would “creat[e] a danger to human health.”
We appreciate the opportunity to summarize the unique benefits of Cayuga’s redevelopment
plan in relation to the energy transition that is underway to create a better energy future for the region
and New York State. The redevelopment plan recognizes and embraces the inevitable role that
renewable energy and natural gas will play in New York’s energy future, while also preserving a viable
business for Cayuga, which in turn will provide long term economic and environmental benefits to
Tompkins County and the region.

Sincerely,

Jerry Goodenough

VP Development
Cayuga Operating Company

i “To accomplish this goal, the Governor will direct the Department of Public Service and the
DEC to work with the New York Independent System Operator to develop a regulatory framework that
will ensure system reliability while facilitating repowering to cleaner fuel or closure no later than 2020. “
(Governor Cuomo 2016 Policy Book, pages 130-31; https:// www.governor.ny.gov/sites/
governor.ny.gov/files/atoms/files/2016_State_of_the_State_Book.pdf)