ML19224A677

Mid-Hudson Nuclear Opponents' Petition to Intervene as Full Party Re Alternate Site Considerations,Need for Facility, Financial Qualifications of Applicants & Cost of Proposed Plant

ML19224A677
Person / Time
Site:	New Haven
Issue date:	03/19/1979
From:	Brown P MID-HUDSON NUCLEAR OPPONENTS, INC.
To:
References
NUDOCS 7905230409
Download: ML19224A677 (3)

Text

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NRC PUBLIC Dor"'ENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

' EL MAR 28 19 7 In the Matter of ) Docket Nos. 9 STN 50-596

) and STN 50-597 New York State Electric )

and Gas Corporation and )

Long Island Lighting Company )

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NYSE&G 1 and 2 ) // ;g A ik D

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• hYf PETITION TO INTERVENE **.

OF MID-HUDSON NUCLEAR g\ @#M, 6 OPPONENTS, INC. ("MHNO")

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MHNO hereby petitions for leave to inte;vene in this proceeding as a full party.

1. MHNO is a New York Not-for-Profit corporation and an exempt organization under Section 501(c) (3) of the Internal Revenue Code.

2. MHNO's principal office is in New Paltz, New York and service upon it should be made t@un Mid-Hudson Nuclear Opponents, Inc.

P.O. Box 666 New Paltz, New York 12561

3. MHNO has approximately 2500 contributing members throughout the Hudson Valley principally in the region south of Albany and North of Newburgh.

4. The primary purpose of MHNO is to act as a spokerman for its members on issues involving construction of electric generating stations and transmission lines, conservation of energy, the uses of nuclear, power and rates charged for electricity. 4lb 34}

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. MHNO has been an active participantin cases both at the Federal and State level involving energy planning and pricing. It is a full party in case 80008, the New York State siting proceeding relating to the same facilities which are the subject of this proceeding.

6. The desi,gn, siting, timing, construction and operation of the facilities for which construction permits in this case are sought will have a significant impact on the followinj interests of MHNO and its menters:

(a) The health and afety of the citizens in the mid-hudson region; (b) The price of electricity available; (c) The ecology of the Hudson Valley ana River, including its aestnetic and historic resources; (d) The course of energy planning in New York State.

7. MENO whishes to participate in the following aspects of this proceeding which affect it.

(a) Alternate site considerations since Hudson Valley sites are the prime alternatives; (b) The need for these f acilities ar '

whether they would be consistent with a long range energy plan for New York State. 18 322

P (c) Ancillary facilities which may be required in the Hudson Valley if the construction permit is granted for the New Haven site.

(d) The Financial and technical ability of the applicants to construct the proposed Jacilities in a manner which would not injure MHNO and its members.

(e) The capital and operating costs of the proposed facilities and the impact of these on rates charged to electric consumers in the mid-Hudson area.

8. Since MHNO represents a distinct mid-Hudson area constituency with interests different than any of the parties to this case, its intervention is necessary to insure that these interests are represented in this proceeding.

9. In addition, through its years of participation in energy matters, MENO has developed a unique expertise on ce-tain aspects of energy planning in New York State which wil' aid the development of a full record in this case.

10. Therefore, MHNO r.hould be permi';ted to intervene in this case as a full party.

March 19, 1979 Peter D. G. Brown Chairman of the Board Mid-Hudson Nuclear Opponents P.O. Box 666 New Paltz, New York 12561 (914)384-6760