Appalachian Mountain Club’s Northern Pass Public Testimony
March 16, 2011
I am Kenneth Kimball, Director of Research for the Appalachian Mountain Club. The AMC appreciates the opportunity to comment on the DOE’s EIS scoping for Northern Pass’s Project. Tonight I will be brief and AMC will be submitting more detailed written comments.
First, some context:
The AMC is a non-profit organization of over 100,000 members and supporters in the Northeast including 10,000 members in New Hampshire. Many visit NH’s State Parks, the White Mountain National Forest, and the Appalachian National Scenic Trail on a regular basis to participate in outdoor recreational activities, thereby supporting NH’s tourism economy.
The AMC maintains over 108 miles of the Appalachian National Scenic Trail in the White Mountain National Forest in NH. The AT is a nationally recognized treasure and a unit of the National Park Service. This project would directly intersect with and negatively impact the Appalachian Trail.
This year the White Mountain National Forest will be celebrating the 100th Anniversary of the Weeks Act that created this Forest. The proposed Project would further scar 10 miles within the White Mountain National Forest.
When setting aside public lands for their outstanding ecological, visual and recreational resources the intent was not to resolve large scale infrastructure right of ways. Permitting the Project as proposed would be the most inappropriate way to celebrate the Centennial Anniversary of the Weeks Act.
Is the Application substantively complete for EIS review?
For the record the AMC believes the Application is substantively incomplete and this process should not have moved into the EIS scoping phase. The Application fails to describe the resources to be impacted, even though it acknowledges that Northern Pass collected considerable site specific resource data. Instead the Application guards that information in “off-limits” mode and in less than 4 pages provides only non-specific, generic topic listings.
The Application has an obligation to describe its proposed mitigation for Project Impacts. Similar to the dearth of information on resources impacted, proposed mitigation is entirely absent in the Application. Surely the Applicant did not believe its proposed project was without sufficient impact that mitigation was unnecessary.
With zero substantive environmental or mitigation information in the Application, though it exists, the public is strongly disadvantaged in this EIS scoping process.
Cumulative Impacts –
The spatial boundaries for cumulative impact analyses required in an EIS should go beyond the site-specific impacts of the transmission corridor itself. The Application claims the project will provide “clean, low carbon hydroelectric power” from Canada. If such benefit is acknowledged in the EIS, it requires a cross the border analysis of the actual power source. For geographic parity the EIS should also describe the negative impacts of these hydroelectric dams on Canadian riverine ecosystems, including but not limited to major river and inter basin diversions, reservoir drawdowns, and the mobilization of mercury into the food chain.
The 2,179 mile Appalachian National Scenic Trail is cumulatively being degraded along its entire corridor from GA to ME by proposed energy projects including wind power and utility corridor projects. This Project would cumulatively add to the degradation of this unit of the National Park Service and its cumulative impact should be analyzed in the EIS.
1) Quantify the irreversible loss, both direct and indirect, of protected open space and fragmentation of the Appalachian National Scenic Trail, WMNF, Conti (and Pondicherry) NWR, NH State Parks/Forests, conservation easement and fee interest lands. These conserved lands are what keep our scenic landscapes scenic, harbor some of our best intact ecosystems and were set aside to protect these values for the public over the long term, not for development purposes.
2) Identify the direct and indirect impacts to lands in the NH Wildlife Action Plan
3) Assess the visual impact along the entire corridor, including visual simulations of the corridor swath and up to 130 foot towers at all key vistas on scenic byways and major highways including the I-93 corridor entering into Franconia Notch, hiking trail overlooks, state designated rivers, and to key recreational and cultural resources such as the Weeks State Park.
4) Describe the potential dollar impact to recreational dependent businesses in the project area and determine if this alteration of the landscape is what people expect and come to see in central and N NH?
5) Assess if this power was on the grid, how it would displace the dirtiest fossil fuels in the region, their cleaner fossil variants, or renewable energy sources under different market and incentive scenarios and timeframes.
6) Quantify power currently generated, consumed and exported from NH today and in the near future and how this project would impact those numbers.
Alternatives to be Analyzed –
The EIS must examine all reasonable alternatives – be they in or out of the State of NH. Alternatives to be examined should but not necessarily be limited to the following:
• The no action alternative – what would the ecological, visual and social impacts be without the project. How would the regions energy markets and local taxes be different without the project?
• How would $1.1 billion invested in energy conservation and efficiency impact the regional job market to implement, reduce air pollution and greenhouse gas emissions, and the US foreign trade deficit compared to the proposed project.
• Burying the transmission line, in part or whole, within existing road or RR ROW corridors in either VT and/or NH. Burying HVDC lines for long distances is both feasible and been done in numerous locations around the world.
• upgrading to a higher transmission capacity the existing above ground DC line through VT and NH that is carrying the same source power
Scoping process –
The AMC requests that after this public scoping period, but before DOE initiates its EIS analysis, that DOE issue an EIS Scoping document for public review on the key elements it intendeds to analyze and how and which alternatives will be analyzed.