NYS Public Service Commission, Article VII (case 18-T-0604)

Letter in Opposition to South Fork Wind, EM&CP Change Request No. 4

Apr 25 - Letter in Opposition, dated April 25, 2022 (click here)

- Exhibits A to J (all) (click here)

Petitions for Rehearing and Stay of NYS PSC (case 18-T-0604)

Apr 16, 2021 - Petition for Rehearing by Simon V. Kinsella (click here)
Apr 16, 2021 - Petition for Rehearing by CPW (click here)
Aug 12, 2021 - Ruling by ALJ Belsito Denying Petitions for Rehearing (click here)

Initial Brief & Reply Brief (by Simon Kinsella)

Jan 20 Initial Brief, dated January 20, 2021 (click here)

- Exhibits A to F (click here)

Feb 3 Reply Brief, dated February 3, 2021 (click here)

- Exhibits 1 to 3 (click here)

Motion to Reopen the Record (January, 2021)

Jan 29 Motion to Reopen the Record, Supplemental Information (click here)

- Exhibits A to O (click here)

Jan 13 Motion to Reopen the Record by Simon V. Kinsella (click here)

- Exhibits A to F (click here)

Motion of South Fork Wind to Strike Testimony (November, 2020)

Nov 16 Response by Kinsella to Motion to Strike Testimony (click here)

November 2020 Motion to Strike Testimony by South Fork Wind

Responses in Opposition to South Fork Wind (eleven)

Responses in Support of South Fork Wind (zero)

NYSPSC Ruling by ALJ Belsito

(click here to see motion, responses, and ruling)

Testimony, Parts 1, 2 & 3 (September to October, 2020)

Testimony of Simon Kinsella, Part 2 - Public Interest and Need (click here)

Topics covered in testimony:

Examination of South Fork RFP
Public interest in the price of energy from South Fork Wind;
Evidence not included in the record for consideration by the Commission:
Examination of South Fork RFP
Power purchase agreement (PPA)
Amendment No. 1 (to PPA);
Uncompetitive procurement process;
Failure to address issues related to:
Peak electrical load/demand
Correlation between peak load, temperature, and energy generation;
Frequency outages during summer;
South Fork Wind's failure to defer need for new transmission lines;
High price of South Fork Wind compared to Sunrise Wind and other facilities; and
PSEG Long Island's conflict of Interest in administering South Fork RFP procurement.

Wind Speed Data:

Summary (exhibit 12); and
Supporting wind data (exhibits 12 (a) to (m)).

East Hampton Transmission Fire (exhibit 13)

Testimony of Simon Kinsella, Part 3 - Rebuttal (click here)

Topic covered in testimony:

Basis of need for facility;
Price passed onto ratepayers;
Existing PFAS contamination of proposed construction corridor;
Developers' admission that its facility is uneconomic; and
LIPA's limited review of Deepwater Wind proposal.