It should be noted that the New York State Department of State recently issued its approval of Islander East's project, stating that it is "consistent" with the State's coastal zone management program, and that "further review...is not required."

Natural gas transport capability on to Long Island must be substantially increased. The robust economic growth in the past several years has created a demand for natural gas in this area that is well above the national average, particularly on the eastern end of Long Island due to residential and commercial growth. Increased power needs have mandated the establishment of new power plants on Long Island for which additional natural gas supplies are essential if these facilities are to be environmentally cleaner and more efficient. Supplying additional natural gas supplies will significantly reduce the region's current high-dependence on foreign oil imports for both production of electricity and space heating.

The New York Independent System Operator (NYISO) has stated that with demand for electricity and natural gas increasing on Long Island, additional gas-fired electric plants will need to be developed, along with the associated expansion of the region's natural gas transmission infrastructure. The NYISO has stated "it is critical that new plants be located "in-city" and "on-island" to maintain reliability, enhance competition and support economic growth. It is clear to us that timely, additional natural gas infrastructure is necessary to support the energy needs for the economic activity and population expansion of this area.

With respect to environmental concerns, Islander East will employ horizontal direct drilling (HDD) technology that minimizes the need to dig a trench in portions of the pipeline route. This HDD technology - which will be used for the maximum feasible distance of approximately 4,000 feet out from the Connecticut shoreline - allows Islander East to dig a single hole and tunnel underground horizontally, thereby minimizing environmental impacts. This technology has been praised by well-regarded environmental conservation organizations for helping to significantly reduce the pipeline's impact on core preservation areas.

In addition, the pipeline will be placed beneath the ocean floor, causing a minimum disturbance to near-shore shellfish beds and other environmentally sensitive areas. Furthermore, offshore construction activity will take place during winter months, when fish and shellfish are less active and therefore less susceptible to disturbance.

We therefore respectfully request that the United States Department of Commerce consider the appeal by Islander East and make a judgement in favor of the project sponsors' position. We would be pleased to work with your office to provide any additional information you may need and to address any outstanding concerns you may have with respect to this matter.

Thank-you for your consideration.