Cuomo Vetoes Port Ambrose Gas Facility: “The Reward Was Not Worth The Risk”

After years of opposition from environmental groups, citizens, and local officials, Governor Cuomo announced today that he has officially vetoed the Port Ambrose Liquefied Natural Gas project. The facility was proposed by Liberty Natural Gas off the shores of New York and New Jersey.

“The reward was not worth the risk and we’re going to veto the Port Ambrose plan,” Cuomo said during an event at the Long Beach Ice Arena Thursday.

With his veto, the proposed facility cannot move forward.

A rendering of the Port Ambrose project.
A rendering of the Port Ambrose project. Photo credit: Port Ambrose

The Governor cited a number of concerns that motivated his decision, but seemed primarily concerned with security, both from terrorism threats and natural disasters. Cuomo also noted that the proposed site for the facility overlapped with the Long Island-New York City Offshore Wind Project as well as important commercial fishing grounds.

Liberty Natural Gas has not yet published a response.

View the full text of the Governor’s letter to the U.S. Maritime Administration here.


From the Governor’s office:

Governor Cuomo Vetoes Port Ambrose Liquefied Natural Gas Project

Governor Andrew M. Cuomo today vetoed the Port Ambrose Liquefied Natural Gas Deepwater Port, citing security and economic concerns along with the potential to negatively impact off-shore wind development. The project, which had been proposed by Liberty Natural Gas, LLC, required approval from both Governor Cuomo and New Jersey Governor Christie under the federal Deepwater Port Act. Governor Cuomo detailed his full position in a letter sent today to the U.S. Maritime Administration.

“My administration carefully reviewed this project from all angles, and we have determined that the security and economic risks far outweigh any potential benefits,” said Governor Cuomo. “Superstorm Sandy taught us how quickly things can go from bad to worse when major infrastructure fails – and the potential for disaster with this project during extreme weather or amid other security risks is simply unacceptable. Port Ambrose would also hinder the local maritime economy in a way that negatively impacts businesses throughout Long Island, and that is simply unacceptable. This is a common-sense decision, because vetoing this project is in the best interests of New Yorkers.”

The Deepwater Port Act requires approval from the governor of each adjacent coastal state before a deepwater port license is issued. For the Port Ambrose project, both New York and New Jersey are adjacent coastal states.

The Governor’s review found that the project posed inherent and unanswered security risks to the region. The potential for catastrophic impacts during extreme weather events was also found to be unacceptable. Additionally, the project posed significant disruptions to commercial and recreational maritime activities, and would also have interfered with a critical off-shore wind power project proposed by the New York Power Authority.

Fate of Port Ambrose Gas Facility Will Be Decided by Cuomo and Christie

The final decision on Port Ambrose, a natural gas facility slated for ocean waters off the coast of Long Island, has now moved to the desks of Governors Christie and Cuomo.

By December 21, the two governors must decide if they will approve, veto, or modify the project. If either governor vetoes, the project will not proceed; if neither acts, it will move forward as designed.

The Port Ambrose facility, which consists of a series of pipelines and underwater buoys, is sited roughly 18 miles south of Long Island and 28 miles east of New Jersey. If built, large ships carrying liquified natural gas would dock at the station where the product would be re-gasified and shipped, via underwater pipeline, to the New York mainland.

Serious Questions

New Jersey Governor Chris Christie and New York Governor Andrew Cuomo stand side by side during a press conference in New York.
New Jersey Governor Chris Christie and New York Governor Andrew Cuomo stand side by side during a press conference in New York. Photo credit: Andrew Burton/Getty

Despite intense public interest surrounding the project, the governors have remained surprisingly silent on their decision.

In October, Cuomo spoke briefly to a reporter from Capital New York about Port Ambrose; it was the first time he had spoken at any length about it.

“The question now goes to the states, New Jersey and New York,” Cuomo said. “There are a lot of serious questions that would have to be answered before approval certainly, because it does bring up a number of obvious security and safety issues.”

Governor Christie has been even more tightlipped, leaving only his past actions from which to draw conclusions.

In 2011, Christie opposed an alternate deepwater natural gas port sited 16 miles off the coast of Asbury Park.

That same year, Christie told an environmental group that he did not believe there was an economic need for liquified natural gas facilities that could come close to balancing environmental risks.

“My opposition to this will continue for as long as I’m governor,” he said.

An Ongoing Battle

Hundreds packed the Long Beach Hotel for a hearing on November 2. Photo via Erik McGregor.
Hundreds packed the Long Beach Hotel for a hearing on November 2. Photo via Erik McGregor.

Opponents of the project say it poses significant security and environmental threats to the region. It is also sited for the same location as the proposed Long Island-New York City Offshore Wind Project.

Opinions differ over exactly how much the port would encroach on the wind farm area. According to a March, 2015 letter by the New York Power Authority, the total wind farm area lost to Port Ambrose would be “a minimum of 13 percent and could be as much 20 percent.”

Supporters of the Port Ambrose project say it will provide needed natural gas supply to areas that have experienced shortages and price volatility.

Federal regulators released the final Environmental Impact Statement in October of this year, and four days of public hearings followed in early November. Written comments from the public will be accepted through November 30.

Port Ambrose Decision Delayed, Feds “Stop the Clock”

The application for Port Ambrose, a deepwater port and gas pipeline off the coast of Long Island, has been delayed by federal agencies.

In a letter posted March 24, the Coast Guard and the federal Maritime Administration “stopped the clock” in evaluating the plan, noting that they lacked the information necessary to complete development of the final Environmental Impact Statement.

The agencies cited four reasons for their delay:

  1. During the comment period, more than 10,000 public comments were received; more time is required to review and respond to this input.
  2. This month, the Army Corps of Engineers began requiring pipelines to be buried 15 feet deep instead of 7 feet, a new rule that will have to be analyzed for the final environmental impact report.
  3. The Environmental Protection Agency must still review the project’s conformity to the Clean Air Act.
  4. “Financial responsibility data” from Liberty Natural Gas is due to on March 30th, and regulators would like time to analyze this information.

The letter did not specify how long the delay could last. This is the second timeline suspension since Liberty’s proposal was published in June 2013.

Bi-Partisan Opposition

The Port Ambrose project would pump liquified natural gas from 900-foot ships through 26-miles of sub-ocean pipeline into the existing natural gas system to serve Long Island.

The port has faced massive public and governmental opposition, especially in recent months. In New York, 52 bi-partisan legislators signed a letter against the proposed plan, urging a veto. In New Jersey, a resolution against the facility has been introduced in both the Senate and Assembly.

On April 1, the New York City Council’s Committee on Environmental Protection and the Committee on Waterfronts will hold a hearing on Resolution #549, which calls on Governor Cuomo to veto Port Ambrose. Under federal law, a veto from either Cuomo or Christie will kill the plan.

Statements Released

Clean Ocean Action, a broad-based coalition of 125 groups, has been a leader in the fight against Port Ambrose. Upon learning of the federal delay, Executive Director Cindy Zipf released the following statement:

“The power of the people, over 60,000 and growing have spoken in strong opposition and overwhelmed the process for the first time. Port Ambrose LNG facility is treading water for now, but the ship isn’t sunk yet. We need all hands on deck and to keep up the pressure. Resolutions need to be passed, petitions signed urging both Governors to veto this dangerous proposal when the application is final. It is clear we have Liberty Natural Gas on the run, but the fight is not over and we will continue to fight until the ship has officially sunk.”

Liberty’s chief executive, Roger Whelan, said stopping the clock is a normal part of the process. “We support the Coast Guard’s efforts to conduct an extensive and thorough federal review and are confident the results will show the Port Ambrose project will have minimal impact on the environment,” he said in a statement.

Opposition to deepwater natural gas port off the Rockaway coast gains powerful ally

Local opposition to a deepwater natural gas facility off the New York City coast has a new ally: Comptroller Scott Stringer.

Stringer joined Council Member Donovan Richards and the Community Board representing the Rockaways yesterday in their demand that Governor Cuomo veto the facility, Port Ambrose, which would be located 22 miles from the Rockaway peninsula and twenty miles off the coast of Long Island.

Port Ambrose “will have negative public health and environmental consequences for our coastal communities,” said Comptroller Stringer. “Liberty Gas [the project’s developer] and the U.S. Marine Administration have failed to provide the public with adequate information or opportunity to comment about expected benefits and impacts of the project. I stand with members of this community in opposition to this project.”

According to Liberty Gas, Port Ambrose would receive gas imports from the Caribbean in order to relieve supply bottlenecks and reduce fuel prices for Long Island residents and businesses. A statement from Council Member Richards’ office refers to Port Ambrose as an “export” facility, a point which is highly disputed by Liberty.

A public comment period on Port Ambrose has just closed. Governors Andrew Cuomo and Chris Christie both have the power to veto the project because of its proximity to the New York and New Jersey coasts.

Opponents are concerned that Port Ambrose may preclude the development of an offshore wind farm slated for the same location.

“Port Ambrose threatens to damage the marine ecosystem and the fishing communities that depend on them,” said the statement from Richards’ office. The project poses “a significant explosion and pollution threat to coastal communities, and increase[s] our dependence on fossil fuels.”

Council Member Richards, Chair of the Committee on Environmental Protection, called the draft environmental impact review for Port Ambrose, released by the U.S. Coast Guard and U.S. Maritime Administration, “a gross mischaracterization of the true impact Port Ambrose will have.”

“The communities of Rockaway and Long Beach strongly oppose this project,” Richards stated.

 

Debate Swirls Over Port Ambrose Project Slated for Long Island Waters

Key Points:

  • Port Ambrose, a deepwater natural gas facility, is being proposed twenty miles off the coast of Long Island and approximately 22 miles from the Rockaway peninsula.
  • The port would import gas in order to relieve supply bottlenecks and reduce fuel prices for Long Island residents and businesses.
  • Opponents are concerned that the facility may preclude the development of an offshore wind farm slated for the same location.
  • There is also fear that Port Ambrose may pose a safety and environmental risk to coastal communities and aquatic habitat in New York and New Jersey.
  • Public comments on the proposal are being accepted until March 16; Governors Cuomo and Christie both have the power to veto.

 


Twenty miles off the coast of Long Island, 103 feet below the surface of the Atlantic Ocean, a battle is brewing—but it’s not just about a natural gas facility being proposed for the site.

In fact, that project has quickly become a proxy for a much larger debate—one that encompasses renewable energy, homeland security, fossil fuels, and the future of New York’s energy resources.

On the sandy, flat bottom of New York Bight, energy company Liberty Natural Gas hopes to build the Port Ambrose Deepwater Project, an underwater system that would transfer imported liquid natural gas (LNG) from ship to pipeline, and eventually to customers throughout Long Island.

Liberty claims that the $600-million project is a necessary addition to the energy infrastructure of the Northeast that would ease supply woes, lower energy costs, and generate significant federal and state tax revenue.

But a wide range of opponents are calling foul on Port Ambrose—in fact, the movement has united anti-fracking activists, Rockaway residents, and even the Republican majority leader of the State Senate. And while concerns vary, most agree that the project would deepen the region’s dependence on fossil fuels and could prevent efforts to construct a major wind farm in the same location.

Public comments on the project are being accepted through March 16th. The project may be vetoed by either Governor Cuomo or Governor Christie.

From Vessel to Buoy to Pipeline

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A LNG vessel unloads at Everett Port, off the coast of Boston. Photo credit: Bob O’Connor

While the debate around Port Ambrose is high-profile, the actual facility would be anything but; aside from the regular presence of large shipping vessels carrying liquefied natural gas to the site, all of the associated infrastructure would be fixed beneath the ocean.

According to Liberty, Port Ambrose has three components:

  1. Newly-built, 900-foot ships that would carry LNG;
  2. A newly-constructed, 26-mile subsea pipeline; and
  3. A buoy system that rests on the ocean floor when not in use.

When a ship arrives at Port Ambrose for a delivery, the 33-foot-tall undersea buoy would rise up and connect to the hull of the ship. The liquid natural gas would be gasified onboard the vessel, and then flow through through the buoy and pipeline into the existing Transco pipeline (operated by Williams Company). The entire unloading process could take as little as five days, or as many as 15.

From there, the natural gas would move into homes and power plants from Long Beach eastward. Liberty estimates that the fuel from each ship could power 1.5 million homes. This short video shows an animated version of the process:

If approved, Port Ambrose would be able to accept LNG year-round, but the company anticipates that deliveries would primarily occur during winter and summer months—meaning for half the year, the port would go unused.

Breaking a Bottleneck

Port Ambrose plans to import natural gas from Trinidad and Tobago, the Caribbean’s largest oil and natural gas producer. Liberty has stated that the increased supply of natural gas would relieve “bottlenecks” and “deliver a new supply of competitively priced gas directly into the downstate New York market, helping to moderate fuel prices in the area.”

But is there a bottleneck? While the supply of domestically-produced natural gas in the United States is increasing (due mostly to shale gas production), the U.S. Energy Information Administration calls New York a “pipeline-constrained” market. This means that pipeline infrastructure in the region is insufficient to meet demand for natural gas, especially during winter months. This can cause price surges on gas and electricity bills, as many power plants are now transitioning from coal to natural gas.

However, as NYER has reported previously, energy companies are rapidly filling this gap (see: Constitution Pipeline, Algonquin Pipeline, and Rockaway Pipeline). In fact the EIA noted just last week that “despite similar cold weather and high consumption [in 2014], the price increases have not been as severe” this winter—thanks in large part to increased pipeline access.

National Grid, the utility company that supplies natural gas to homes and businesses on Long Island, declined to comment on price spikes or whether Port Ambrose might mitigate them, stating only that “at the present time, we have not evaluated this particular project, and as a result, do not have an expressed opinion on this proposal.”

A Growing Coalition

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Councilman Donovan Richards speaks before a public hearing on Port Ambrose. Photo credit: Minister Erik McGregor.

Not everyone agrees that New York needs a project like Port Ambrose. Relieved of duty now that Cuomo has banned fracking, the state’s vocal anti-fracking activists, many under the umbrella of Sane Energy, have re-calibrated to challenge fossil fuel development in all forms. The No LNG Coalition, a loose group of more than 100 environmental and activist organizations, has also been coordinating the anti-Port Ambrose movement.

Elected officials—from New York and beyond—have begun issuing statements against the proposed facility, too. Many hail from New York City, coastal New Jersey, and Long Island. New York City and New Jersey will not receive any fuel from Port Ambrose, but, they argue, because of the project’s location, these localities will bear the brunt of any safety or environmental impacts first.

State Senator Brad Hoylman (D-Manhattan), the ranking Democratic member on the Senate Environmental Conservation Committee, has called the project “unnecessary and environmentally irresponsible.”

New York City Councilman Donovan Richards recently introduced Resolution 0549, calling on Governor Andrew Cuomo to veto the application by Liberty Natural Gas. He was joined by Council Members Margaret Chin, Corey Johnson, Rosie Mendez, and Eric Ulrich. “New York State cannot afford to accommodate the natural gas industry any further considering the immense environmental costs associated with the extraction, production and transportation of natural gas in any state,” Richards told NYER.

Surprising some, pro-fracking Senate Republican Leader Dean Skelos also submitted a letter to Governor Cuomo against Port Ambrose, stating, “while the need for increased energy sources are critical to the continued success of our state and local economies, the negative impact of the Port Ambrose LNG proposal on the local community has the very real potentially [sic] of outweighing any perceived benefits.”

Other New York officials that have spoken out against the port include Assemblyman Phillip Goldfelder (D-Ozone Park), Assemblyman Todd Kaminsky (D-Lawrence), and Long Beach City Councilman Anthony Eramo.

A Symbolic Battle Between Old and New

From damage to the environment to terrorist attacks, the list of concerns varies by organization and individual. However, almost all unite over one specific frustration: New York’s continued reliance on fossil fuels.

Bringing this issue front and center is the fact that Port Ambrose is slated to be built in the exact same area proposed as a home for 200 wind turbines. The Long Island – New York City Offshore Wind Project, which could yield enough electricity to power 245,000 homes, is currently working its way through a multi-year federal review process.

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The two red dots represent the position of the LNG buoys; the dotted line shows the proposed new undersea pipeline. The green triangle represents the leasable area available for a proposed wind farm. The lavender triangles represent shipping lanes–areas that are off limits for development and require extensive buffer zones. Map via Sane Energy.

Liberty maintains that the two projects are compatible, and states that Port Ambrose will only require 2.4 square miles, or 4 percent, of the 127 square miles needed for the wind project.

Opponents disagree outright with this assertion, viewing the competition over the space as a symbolic battle between renewable and fossil fuels. Kit Kennedy, Director of Energy and Transportation for the Natural Resources Defense Council wrote, “New York State and New Jersey have worked hard to recover from the devastating impacts of Superstorm Sandy…” She continued, “It would be the height of irony—and a damaging energy policy—to privilege the construction of a fossil-fuel import facility over a much-needed and long-overdue renewable offshore wind farm.”

The Bureau of Ocean Energy Management seems to share these concerns. In comments submitted to the USCG during its review of the Port Ambrose Deepwater Port Application in 2013, BOEM stated they were “concerned that the proposal to construct a LNG Port in the same area proposed for a large wind facility could result in serious conflicts—or at the minimum, complicating factors—that may impact the overall viability of one or both projects.”

The Export Question

Opponents also suggest that Port Ambrose may eventually become an export facility, sending natural gas produced by fracking in the Marcellus Shale region to higher-priced European markets. They point to projections from the EIA that show the U.S. becoming a net exporter of natural gas by 2020.

While the EIA data refers to the U.S. as a whole and not just the Northeast, the claim is not without some precedent: Both Jordan Cove in Oregon and Dominion Cove Point in Maryland began as LNG import facilities and have since been permitted to export.

Liberty Natural Gas strongly asserts that Port Ambrose will be an import-only project that will not have the technology needed to export gas.

This point is reiterated in the DEIS: “The considerable technical, operational, and environmental differences between import and export operations for natural gas deepwater ports is such that any licensed deepwater port facility that proposed to convert from import to export operations would be required to submit a new license application…and conform to all licensing requirements and regulations in effect at such time of application.”

Roger Whelan, CEO of Liberty Gas, told NYER: “The Port Ambrose project is an import only project—no exports will take place from the facility…The project’s safe, state-of-the-art technology can only be used to regasify and deliver natural gas, not export it… Port Ambrose will never be an export facility.”

Worth the Risk?

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A woman walks on the sand at Long Beach, NY. Photo credit: Amarit Opassetthakul/Creative Commons.

Finally, there is lingering concern that Port Ambrose may pose a risk to coastal communities and aquatic habitat in New York and New Jersey. These risks, opponents say, could come in the form of habitat destruction during construction or operation, or possible terrorist attacks on the facility or LNG vessels.

“It is irresponsible to site a potential terrorism target like this near a residential and commercial hub,” reads the No LNG Coalition website, reiterating concern over intentional or accidental LNG leaks, explosions, or fires. “To put it mildly, this port presents a significant safety and security risk to the people, first responders, commerce, economy, and environment of the Mid Atlantic Ocean.” 

Daniel Mundy Jr., Rockaway resident, battalion chief for the FDNY, and Vice President of Jamaica Bay Ecowatchers, told NYER, “There’s nothing in the books written anywhere that would tell you how to handle a situation should one of these types of ships become the terrorist target that’s driven towards shore.”

Liberty Natural Gas notes that as part of the approval process, Port Ambrose has undergone a Risk Assessment by the US Department of Homeland Security, which concluded that the facility poses no danger to the public.

The Draft Environmental Impact Statement for Port Ambrose asserts that the project also constitutes no significant risk to the natural environment. Liberty maintains that they have chosen the project location and route intentionally to avoid critical habitat and fishery areas, and will employ “state of the art plow technology” to install the 22 miles of required subsea pipeline.

The No LNG Coalition contests this point vigorously, claiming that the DEIS does not adequately analyze the risks of the port to threatened and endangered species. Cassandra Ornell, staff scientist for Clean Ocean Action, said that “construction of the pipeline … would involve dredging of the sea floor, destruction of undersea habitats, smothering of bottom-dwelling species and increasing the turbidity of the water.”

The Timeline

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Community members speak at a public hearing for Port Ambrose in Queens, NY. Photo via Facebook.

Currently, the 1,800-page Draft Environmental Impact Statement on Port Ambrose is going through the public comment phase of the review process. Two public hearings have been held (in Eatontown, NJ and Queens, NY) and comments are now being accepted online until March 16, 2015. After a final EIS is issued this spring, Governors Cuomo and Christie will have 45 days in which to issue a veto—if no action is taken, approval would be presumed.

If you believe Long Island needs a new source of natural gas, or you’re concerned about the effects and risks of Port Ambrose, please consider submitting your comments; you can do so electronically (click Submit a Formal Comment), or via fax or mail.

You can also browse comments that have already been submitted here.

Major Wind Farm Off Rockaway Coast Reviewed by Feds

Almost 200 3.6-megawatt wind turbines may eventually be constructed 13 miles off the Rockaway Peninsula. Described as what could be the largest offshore wind farm in the United States, the Long Island – New York City Offshore Wind Project is working its way through a multi-year federal review process.

The wind farm could yield as much as 700 MW of energy—enough electricity to power an estimated 245,000 homes.

The project is a collaborative effort between Con Edison, the Long Island Power Authority, and the New York Power Authority. LIPA submitted the proposal to federal regulators in September, 2011.

To date, no wind farms have been constructed in U.S. federal waters (more than three nautical miles off-shore). But several projects are grinding toward execution. The Bureau of Ocean Energy Management has issued seven commercial leases for offshore wind farms. Several other wind projects are now in the initial review stages.

Plans for wind farms in state-managed coastal waters are also underway. A competitive auction for possible developers of a wind demonstration project off the New Jersey coast is to be held on January 29th, a BOEM spokesperson said.

A Plan for Our Coastal Waters

As the Rockaway wind farm project is being reviewed, a full-scale comprehensive planning effort for the mid-Atlantic coastline is underway. Government regulators and advocacy groups say that the wide array of potentially competing uses in coastal waters—from commercial fishing to energy projects to military exercises to tourism—requires more public direction.

Public meetings regarding how best to manage New York’s coastal waters, and those of neighboring states, are taking place this week in Manhattan’s Javits Center. The meetings are led by the Mid-Atlantic Regional Council on the Ocean, a partnership of the state governments of New York, New Jersey, Delaware, Maryland, and Virginia.

Could a Rockaway Wind Farm be Commercially Viable?

Developing a major wind farm off the coast of New York City is not seen as far-fetched by the private sector. Tracey Moriarty, a spokeswoman for the Bureau of Ocean Energy Management, told NYER that other potential wind farm developers have expressed interest in the site off the Rockaways.

“Wind has transitioned from an expensive green energy propped up by legislative support to a bona fide player that competes shoulder-to-shoulder with gas and coal for large generation projects,” noted a March, 2014 article in Business Insider.

“If natural gas prices go up any faster, wind power may even run at a discount to all major generation sources by 2018,” BI concluded.

And the Rockaway wind farm may even be able to out-compete other New York State wind projects.

“An offshore wind facility of this size has distinct advantages over inland options,” says the Con-Ed, LIPA, NYPA collaborative. Off-shore wind power will ultimately be cheaper and more reliable than wind power generated upstate, they say.

“In contrast to land-based wind facilities in remote regions of the state, ocean-based wind power is stronger, more consistently available, and can be situated closer to Long Island and New York City,” the collaborative notes.

“Land-based wind power availability tends to diminish during the hottest part of a summer day, which is precisely the time that Long Island, New York City and Westchester customers use the most electricity.”

A Long Way to Go

The Rockaway wind project is intended to help New York State reach its goal of meeting 45 percent of its electricity needs through improved energy efficiency and renewable sources by 2015. According to BOEM spokeswoman Tracey Moriarty, the project still has a long way to go.

The Rockaway wind farm is at the beginning of a four-step process.

First, BOEM must conduct a preliminary environmental review of the potential impacts of a wind farm in the proposed ocean site. The public will be able to submit comments as part of the review.

Second, a lease to develop the wind farm in federal waters is issued to the winner of a competitive auction process.

Third, a site assessment plan is developed, which involves the collection of more information (e.g., wind speed data, biological data) about the area proposed for development.

And finally, the wind farm’s developer submits a construction and operations plan. BOEM must then carry out a full environmental review of the project.

Moriarty said that BOEM is now completing an “Area ID” (i.e., identifying the Wind Energy Area). This is a necessary step before they can even begin the preliminary environmental review.

Balancing Renewable & Fossil Fuel Energy Projects Off the New York Coast

As the Rockaway wind farm review moves forward, the New York coast is also being examined as a possible site for a liquid natural gas facility. Liberty Natural Gas and West Face Capital have proposed to build a deepwater port in federal waters approximately 19 miles from the New York shore.

The facility, Port Ambrose, would consist of a submerged buoy system, which its developers say would be used to receive natural gas deliveries from the Caribbean.

In a June, 2014 letter to BOEM, Liberty argued that the two projects could co-exist. “Liberty believes that with proper siting and mitigation measures in place, one or more wind farms can be developed in the Call Area near Port Ambrose,” the company wrote.

“The minimum navigation requirements for Port Ambrose will total less than 4% of the 127 square mile Call Area, providing approximately 122 square miles of space for wind farm development,” they maintained.