The replacement project was challenged by the PEAK Coalition (New York City Environmental Justice Alliance, UPROSE, THE POINT CDC, New York Lawyers for the Public Interest, and Clean Energy Group), along with Earthjustice, Sierra Club and Chhaya CDC. The organizations submitted joint comments to the New York State Department of Environmental Conservation (DEC) in opposition to NRG’s draft air permit application and environmental impact statement. The comments detail the many ways in which the proposed gas plant is inconsistent with CLCPA emissions mandates and highlight disproportionate harm the project would have on disadvantaged and overburdened communities, again in violation of the CLCPA.