DEBORAH ROE, Granby, CT.
To the Commissioners:

I am writing to oppose the proposed Constitution and Wright Interconnect Pipelines. From a technical, environmental, and economic standpoint, the record does not support a finding that these projects are in the public interest or are necessary to meet regional energy needs.

The ecological impacts of new pipeline construction in the Northeast are significant and should be evaluated in the context of cumulative stressors already affecting regional ecosystems. The region is experiencing measurable declines in biodiversity driven by a combination of climate change, land-use change, and habitat fragmentation. Linear infrastructure such as pipelines introduces persistent edge effects, disrupts wildlife movement corridors, and alters hydrology and soil structure. These impacts are not fully mitigable and can persist for decades. Given existing pressures on forest and wetland systems in New York and New England, additional fragmentation is likely to exacerbate already documented declines in wildlife populations and ecosystem resilience.
From a climate perspective, expansion of methane infrastructure presents a clear inconsistency with current scientific understanding and regional decarbonization pathways. Methane is a high global warming potential greenhouse gas, particularly over near-term time horizons that are critical for climate stabilization. Emissions associated with natural gas systems are not limited to combustion; upstream production, processing, and downstream transmission all contribute to lifecycle emissions. Empirical studies have shown that fugitive emissions from pipeline systems are systematically underestimated, raising questions about the true climate impact of expanded gas infrastructure. Approving long-lived assets that depend on continued methane throughput effectively commits the region to a higher emissions trajectory at a time when policy and planning efforts are oriented toward rapid reductions.

The economic rationale for the project is also unconvincing. The premise that increased pipeline capacity will materially reduce consumer energy costs is not supported by observed outcomes in the Northeast. Over the past decade and a half, substantial investment in gas infrastructure has not resulted in sustained reductions in electricity or heating costs. Instead, rate structures allow pipeline developers to recover capital and operating costs through regulated tariffs, with those costs ultimately borne by ratepayers. This model socializes financial risk while providing relatively high, stable returns to project investors. In effect, it functions as a transfer mechanism from consumers to infrastructure owners, rather than as a market-driven response to demonstrated demand.

On the question of need, the available evidence suggests that additional firm gas capacity is not required to maintain system reliability. Load growth in the region is increasingly being offset by energy efficiency gains, demand-side management, and the deployment of distributed energy resources. Electrification of heating and transportation, coupled with renewable generation and storage, is altering load profiles in ways that reduce dependence on fossil fuel peaking resources over time. In this context, new pipeline capacity risks becoming underutilized or stranded, while still imposing long-term cost obligations on consumers.

Finally, the proposed projects appear misaligned with broader state and regional policy frameworks. States across the Northeast have adopted statutory greenhouse gas reduction targets and are actively pursuing strategies to decarbonize the energy system. Investment in new methane transport infrastructure is difficult to reconcile with these commitments, particularly given the expected operational lifetime of such assets.

For these reasons, the proposed pipelines do not meet the standard of public convenience and necessity. The environmental externalities, climate implications, and cost burdens are substantial, while the demonstrated need is limited or absent. I respectfully urge the Commission to deny approval.

Respectfully submitted,
Deborah Roe