Immediate Action Required


Immediate Action Required!!!!

Arlington (Crestwood’s subsidiary on Seneca Lake) has just asked for a 2 year extension on their methane expansion project (the original order expires in May 15th of this year). We have an extremely short window of time to get FERC to deny this request, and we need a massive Advocacy Campaign to:

1.) Call Cuomo  1-518-474-8390 and ask him  to write to FERC, asking them not to issue a 2 year extension for Arlington Natural Gas expansion. Choose option 3 to talk to a live person. Here’s what you could say,

“I’m calling to tell Governor Cuomo that we appreciate that he hasn’t given Arlington, the company that wants to expand natural gas storage on Seneca Lake, an underground storage permit, and we don’t think that he should grant it. Arlington has had plenty of time to ensure that it could meet its deadline, and it sat on its rights. The community doesn’t want more gas storage, and the region does not need it. There’s a glut of gas on the market, the need assessment that was done in 2014 is no longer valid, and the project therefore is no longer in the public convenience and necessity.  We look to Governor Cuomo for leadership in the shift away from fossil fuels.  Please tell FERC not to issue the extension to Arlington.”


If Cuomo/DEC tells FERC to deny this request, this would be huge.

2.) Submit a letter to FERC into the docket: Arlington Storage Company, LLC, Docket No. CP13-83-000 , asking that they deny this extension, because there is no longer any reason to go forward.

We have a short instructional video that shows how to comment, then under the video written directions along with a sample comment that you can use.

Step 1: Write the letter. Use your word processor (MS Word, etc) or a text file (feel free to use text from the attached letter).

Step 2: Go to FERC’s web site:

Step 3: Click anywhere in the box that says “eComment: Does not require eRegistration” (The “eComment” text has a bright orange background).

Step 4: Fill out the form with your name, address, etc. FERC will send you an email message.

Step 5: Go to your email app. Open the message from FERC (“FERC eComment Request” is the subject line”).

Step 6: Click on the link in FERC’s message.

Step 7: You’ll see the information you entered earlier (name, address, etc). Paste the text of the letter you wrote into the empty text box at the bottom of the form.


Please feel free to use any or all of the talking points below, or you can take talking points from the letter that was submitted to FERC by Earthjustice on our behalf or our letter to Governor Cuomo. Make sure to add your name at the bottom:

Talking points:

  • Arlington failed to move forward with its planned expansion and therefore will miss its in-service deadline.
  • To salvage the project, on January 28, 2016, Arlington applied for an extension of the deadline that would double the time allotted for construction.
  • The economics of gas production and consumption have changed materially since May 15, 2014, when FERC approved the Arlington project.
  • Arlington’s parent company has announced a new joint venture reflecting those changed conditions.
  • FERC should deny the Arlington’s request for an extension and require a new application for the storage expansion project, so that the new economic facts can be subject to public scrutiny and can be incorporated into FERC’s public interest determination.

Sample letter:

To: Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission


Dear Ms. Bose,


I am submitting this letter to request that FERC deny Arlington Storage Company LLC an extension for their methane storage expansion project.

Arlington has had plenty of time to ensure that it could meet its deadline, but instead it sat on its rights. In the meantime, market conditions have changed, and we have a glut of gas. The need assessment FERC did in 2014 is no longer valid, and the project is no longer in the public convenience and necessity. Arlington is not entitled to keep the project in the pipeline in the hope that market conditions will change.

The community in which this expansion would be housed does not want the project, as is evidenced by the 31 municipalities, representing 1.2 million New York residents, which have passed resolutions opposing hydrocarbon storage on the shores of Seneca Lake. Given both the community’s concerns, and the lack of need for more storage, the project cannot be said to be in the public interest.

If Arlington wants another two years in which to build the project, FERC should deny the extension, rescind the order authorizing construction, and start the application process over again. There’s a reason there’s a time limit on FERC’s orders.


Respectfully submitted