Comments by Jane Difley at the Pembroke DOE Scoping Hearing

My name is Jane Difley and I’m the President/Forester of the Society for the Protection of New Hampshire Forests. I’d like to welcome you to New Hampshire. I think that over the next seven days you will hear why we feel strongly that this is a particularly special place.


We hope that you take seriously what you hear in New Hampshire this week as you consider the scope of your Environmental Impact Statement. Those in favor of Northern Pass have worked hard to create the impression that permitting of this proposal is inevitable, a matter not of “if” but “where and when”. Your presence here tonight reminds us that before any decisions are made about Northern Pass, the people of New Hampshire have an opportunity to be heard. And you will likely learn that we are not at all bashful. We are glad that you have come to listen.

The Forest Society is a private, non-profit membership organization with 10,000 member households. We were organized in 1901, and in 1904 our Board of Trustees adopted a mission statement that still guides us today: to perpetuate the forests of New Hampshire through their wise use and their complete reservation in places of special scenic beauty. At our solar headquarters in Concord, we have modeled the use of renewable energy systems and advocated energy conservation and sustainable energy policies for decades.

We are also NH landowners with171 forest reservations in 96 New Hampshire communities permanently conserving 50,000 acres of working forests. We also hold more than 700 conservation easements. And over the past 110 years we have participated in collaborative efforts that have created the White Mountain National Forest, as well as state forests and state parks, and protected privately owned working forests.

As the state’s oldest largest land trust, we have a legal and ethical obligation to protect and steward the lands we have helped to permanently protect from disruptive and damaging development. In the towns where Northern Pass is proposing to construct this new power line, the Forest Society holds conservation easements on 89 separate properties protecting 18,660 acres of land, and we own 18 forest reservations totaling 5,269 acres. Because of their scenic, ecological, natural resource and recreational values to the public, these lands were conserved to protect them from future development, including that proposed by Northern Pass.

We also must defend the broad scenic landscapes we have spent 110 years protecting, including the White Mountain National Forest. In New Hampshire our landscapes are a very large part of our economy and our culture, so a new blight on the landscape is also a new injury to our well being.

But we also acknowledge that there are a host of questions about this proposal that are today unanswered. We hope your EIS will be broad in scope and geography in order to answer those questions.

Given that the impact the Northern Pass proposal would have on 180 miles of New Hampshire landscape, we feel strongly that there must be a determination of true public need and benefit for New Hampshire citizens. If you find there is no such clear public benefit, we urge you to deny the Presidential Permit.

We also urge you, in evaluating the ecological, economic and social impacts of this proposal, to envision and rigorously analyze a broad range of alternatives, among them the “no action” alternative. As a nation we should adhere to the tenet of medicine and ‘First, do no harm”.

The EIS should also carefully examine alternatives that may offer fewer negative impacts on the environment and economy. If this energy is truly for regional needs, please don’t limit your examination of alternatives to New Hampshire’s geography.

The public’s interest also demands careful examination of alternatives using existing HVDC corridors--even if those corridors are controlled by corporate entities other than the applicant.

We also urge you to not limit your analysis to above-ground cables on 90 to 135-foot-high towers. Our state’s economic, environmental and energy future deserves creative new thinking beyond the current narrowly-conceived proposal.

We recommend that you:

• Require the creation of the best visual impact analysis that current technology can provide for every mile of every alternative; the public needs to be able to visualize the impacts of each alternative.

• Require a rigorous economic and environmental analysis for each alternative; looking not only at those purported economic benefits, but also look at the economic costs, including impacts on property values, on local economies, and on New Hampshire’s brand as a place to live and visit. Only a thorough understanding of all costs and benefits can lead to a well informed decision.

• Collaborate closely with the Sate of New Hampshire. It is likely that your EIS will also be used to inform siting decisions made by New Hampshire’s Site Evaluation Committee. We strongly recommend that you coordinate directly with the Chairman of the SEC as you scope the boundaries of this EIS and prepare the draft, to assure that the information needs of federal and state decision-makers are served by your analysis.

We would like common sense and public benefit to prevail. Our request is that you accept the challenge and look at your work on this EIS as an opportunity to set a new standard for the public review of such a proposal. When you issue your record of decision for the Presidential Permit, make it the best informed record of decision that has ever been issued by the Department of Energy.

There has been a suggestion that the opposition to this project as proposed is simply a NIMBY, or “not in my backyard” reaction to visual blight and ecological harm. It is unfortunate that the proponents of Northern Pass do not consider 180 miles of New Hampshire part of their own back yard. We do. In fact, the Weeks Act was signed 100 years ago this month to establish the eastern National Forests—most notably the White Mountain National Forest—in large part because the nation recognized that our forested landscape was its back yard, and that protecting our timber, water, wildlife and tourism resource was paramount. We believe this is more true today, not less.

Thank you for listening and for recognizing the critical role our landscape plays in our economy and our way of life.