Environmental Justice for ISO NE

Gordon Van Welie
President and CEO
ISO New England, Inc.

Dear Mr. Van Welie:

We, the undersigned organizations and New Haven residents, are deeply concerned about the adverse health effects of air pollution. Recently, many of us took part in the negotiation with PSEG (as mandated by the 2008 Environmental Justice Law) to keep the three peak power units proposed for Harbor Station from adding to our pollution burden.

It has become glaringly clear that the high incidence of health problems related to unlawfully high levels of air pollution in New Haven and other EJ communities has not been brought about by the power companies alone but is rather the cumulative result of a systemic failure to protect human health in the course of producing and managing the power supply. Thus, to end this untenable situation, all participants in the system, including ISO NE, must adopt policies and procedures that will result in all areas of our region meeting EPA air quality standards.

What’s happening at Harbor Station illustrates the systemic nature of the problem. DPUC’s decision to place three peak power units next to a 450 MW plant in an urban community that is out of attainment for PM 2.5 and ozone and has the highest hospitalization rate for asthma in the state shows a staggering disregard for the public’s well being. Equally dismaying is the absence of any statutory regulation banning such a placement. When the “peakers” come on line, however, ISO NE’s management of the power supply will be critical in determining their impact on health. If, as we have been told, ISO NE does not consider local air quality when deciding which power plants to activate, we fear that at times of peak power demand (on hot, humid summer days when air quality is at its worst and on cold winter days when PM2.5 levels are unsafe for sensitive groups), ISO NE could well call upon all four units at Harbor Station to run at full capacity, thereby generating unprecedented levels of air pollution precisely when sensitive groups would be most at risk.