Cxm-CAA. • # NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT In the matter of the application by Astoria Energy LLC for a Certificate of Environ- Mental Compatibility and Public Need to CaseNo. 99-F-1191 Construct and operate an approximately 1000 megawatt Generating Facility in the Astoria section of Queens County. ARGUMENT IN SUPPORT OF APPLICATION FOR PARTY STATUS Submitted by: NEW YORK INSTITUTE OF LEGAL RESEARCH . Herman A. Stuhl Chairman of the Board David H. Klein General Counsel Judith A. Koskella, Ph.D. Director Environmental Bureau Post Office Box 398 Yorktown Heights, New York 10598-0398 Tel. No.: (914) 245-8400 Fax No.: (914)245-7660 E-mail:
[email protected] April 4, 2001 NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT In the matter of the application by Astoria Energy LLC for a Certificate of Environ- Mental Compatibility and Public Need to CaseNo. 99-F-1191 Construct and operate an approximately 1000 megawatt Generating Facility in the Astoria section of Queens County. ARGUMENT IN SUPPORT OF APPLICATION FOR PARTY STATUS Submitted by: NEW YORK INSTITUTE OF LEGAL RESEARCH Introduction In accordance with the directive of Administrative Law Judge J. Michael Harrison, given during the hearing held on March 23, 2001 at the New York City Offices of the State of New York Public Service Commission, the New York Institute of Legal Research ["the Institute"] respectfully submits this argument in support of its motion for active party status. Summary of the History of the Institute's Involvement with this Case Practically since the filing of the pre-application report on August 31, 1999, the Institute, acting as a pro bom public advocate, to, inter alia, help present a full and complete record to the New York State Board on Electric Generation Siting and the Environment ["the Board"] and to protect the public from what we believe to be an ill- conceived and dangerous project and, from the beginning, the applicant has steadfastly resisted the Institute's efforts.