20Q9 fl," Y I B e;," 10: 21 NRDC NATURAL RESOURCES DEFENSE COUNCIL THE EARTH'S BEST DEFERS[ May 15, 2009 By Email and Regular Mail Rudy Stegemoeller, Administrative Law Judge New York State Department of Public Service Three Empire State Plaza Albany, NY 12223-1350 Re: Case 09-S-0029, Proceeding on Motion of the Commission to Consider Steam Resource Plan and East River Re-powering Project Cost Allocation Study, and Energy Efficiency Programs for Consolidated Edison Company of New York, Inc. Dear Judge Stegemoeller, The Natural Resources Defense Council and Riverside South Planning Corporation are writing to request the additional analysis that Con Edison complete as part of the work in Case 09-S-0029. This request entails an assessment of alternative cases for the 59th Street Generation Station that parallels the Hudson Avenue Steam Station assessment. 59°' Street Generating Station At the March 31, 2009 Technical Conference in this proceeding, the Natural Resources Defense Council (NRDC) and the Riverside South Planning Corporation (RSPC) made a presentation on the status of the Riverside South development, the additional development that has taken place around the 59`s Street Generating Station, and the additional approximately 4.8 million square feet of new development immediately contiguous to the Station that is pending before the City Planning Department. We have attached a modestly updated and corrected copy of the material provided to the parties before the Conference and will be happy to provide a copy of the slides used in the presentation upon the request of participants. Pursuant to the Mayor's P1aNYC policies, the City Planning Department has required the developer of Riverside South, Extell, to assess the viability of creating an energy district to provide the electric, heating and cooling requirements of the new development with a cogeneration system. In addition, the developer immediately south of the Generating Station, the Durst Organization, has expressed a willingness to assess the viability of building a cogeneration plant on its property that would be sized to meet the requirement of the new development and to replace the power provided by Generating Station. 40 West 20 Street washington, dc • los angeles • san francisco • new york • chicago • beijing New York, NY 10011 tel 212 727-2700 fax 212 727-1773 In a related matter, the NYC Landmark Preservation Commission has recently set a date for a public hearing to consider designating the outside of the 59th Street Station as a landmark. Built in 1904 to power New York City's first subway, the Interborough Rapid Transit (IRT) Powerhouse occupies an entire city block from West 59`s to 60th Street between Tenth Avenue and the West Side Highway. McKim Mead & White designed this massive public building. It is part of the uplifting, civic-minded architecture of the City Beautiful movement on a par with other New York City Beaux-Arts designated landmarks such as the New York Library, the Metropolitan Museum of Art and the Farley Post Office. Consolidated Edison took over the facility in 1960. Con Edison has largely removed the antiquated electric equipment and installed steam boilers, but only occupies approximately 12% of the interior space today. Because Consolidated Edison utilizes only a small portion of the interior space in the Powerhouse, NRDC and RSPC have requested that the City develop a proposal for the conversion of the Generation Station to a Cultural/Community Center. By way of example, the Tate Modem Museum in London was renovated from a powerhouse to a world-class cultural center. It is very similar to the inside of the Con Edison Power Plant. We believe that consideration of this alternative could lead to a major enrichment of the area, both economically and culturally, and enhancement of the proposed new development at Riverside South. In support of the City effort, the NRDC and RSPC seek an assessment by Con Edison of alternative means of meeting the power requirements of the new development yet-to-be-built around the Generating Station and to assess the feasibility, costs and benefits of building a new cogeneration plant that replaces the power from the Generating Station. We request that Con Edison provide an assessment of the costs and benefits to Con Edison and the ratepayers if the plant is retired as a source of steam and is replaced by a new cogeneration plant immediately to the north or south of the Generating Station, or at another suitable location on the same network. The analysis should consider at least two different sizes for a new cogeneration plant as follows: • Cogeneration that is sized to replace the steam produced by the Generating Station, and • Cogeneration that is sized to replace the steam produced by the Generating Station and to meet the electric, heating and cooling requirements of the new development. Further, we request that in addition to the analysis provided for the Hudson Avenue Steam Station assessment, the assessment consider alternative dispatching regimes, include the cost of decommissioning the Generating Station, afld specify the space required and the impact on the consumption of City water. At the technical conference, Con Edison said that the space in the building was being more fully utilized than indicated by the pictures in the presentation by the RSPC. We believe that almost all of the lower levels are used for storage of pipes and other equipment, and that the main floor is largely vacant except for a training station for inspectors and the temporary storage of the equipment needed for water treatment. We request that Con Edison provide a detailed assessment to the degree to which it utilizes the space available in the building (including a floor plan for each floor), identify the purposes for which the space is utilized and, importantly, if the stated purposes are permanent or temporary. Respectfully submitted, 40 West 20 Street washington, dc • los angeles • san Francisco • new york • chicago • beijing New York, NY 10011 tel 212 727-2700 fax 212 727-1773 Brandi Colander Attorney Natural Resources Defense Council 40 West 20th Street, 11th Floor New York, NY 10011 (tel) 212-727-4480 (fax) 212-727-1773 Paul J. Elston, President Riverside South Planning Corporation 99 Park Avenue, Suite 2200 New York, NY 10016 (tel) 212-370-3630 (fax) 212-599-6282 cc: Consolidated Edison Active Parties 40 West 20 Street washington, dc • los angeles • san francisco • new york • chicago • beijing New York, NY 10011 tel 212 727-2700 fax 212 727-1773 Natural Resources Defense Council (NRDC) and the Riverside South Planning Corporation (RSPC) Presentation on the 59th Street Generation Station at the 09-S-0029 Con Ed steam March 31 technical conference The 59th Street Generation Station is located in the midst of a large amount of new residential development and contiguous to two new waterfront parks that are part of the Hudson River Greenway. The NRDC and the RSPC believe the 59th Street Generation Station may be relatively inefficient and polluting when compared to a combined heat and power plant that would serve electricity, cooling and heating needs of 4 million square feet of new development and replace the power currently produced by the Generating Station. The Generation Station is located in a landmark building and the interior is severely underutilized. The RSPC has urged the City to develop a plan for converting the plant to a public use, such as the Tate Modem of London. In this document we will discuss the: - Status of the Riverside South development - History and current operation of the Generation Station - Landmark qualities of the building and conversion to a Cultural/Community Center The Riverside South Development The Riverside South development project includes 7.9 million square feet of new residential buildings and a 21.5-acre waterfront park that is part of the Hudson River Greenway. The development is about 60% completed. I. 315 West 61- Street 2 Freedom Place South 3 Manhattan West Park 4. Avery 5 Rushmore - just opened 6 59t IRT Street Powerhouse 7 Durst Organization Property 8. John Jay (CUNY) 9 10 West End Avenue to. Amsterdam Houses 11. Lirroki Center 12. Fordhom University 13 Time Warner Building 14 Lincoln Towers 15 Hudson River Park 16 Waste Transfer Station I The plan for the development that was approved by the City Planning Commission grew out of a collaboration between Donald Trump, the original developer, and the RSPC, a non-profit corporation that represents the interests of its seven member organizations - the Municipal Art Society, the Regional Plan Association, New Yorkers for Parks (formerly known as The Parks Council), the Riverside Park Fund, Westpride, Natural Resources Defense Council and the New York League of Conservation Voters. In 2004, Extell Corporation purchased the site and development rights and obligations from Hudson Waterfront Associates, and organization headed by Donald Trump. The 591h Street Generating Station at the edge of the project may provide an extraordinary opportunity to create a spectacular public space and provide the anchor for a vibrant connection for the local community to the waterfront park. The NRDC and the RSPC plan to work with the City to evaluate the energy efficiency and economic efficiency of the current operation at the Con Ed plant and to develop alternative energy strategies for meeting the energy requirements of the proposed new development and the Con Ed steam system. Approximately, 53% of the buildings have been built - buildings A-I and 0, which account for approximately ; C_:c 4,167,942 square feet ofuseable < o,!Lb C square feet out of the total of 7,898,074 authorized by the City. A " building on Parcel J (480,935 square feet authorized) is under construction.