Forest Society Motion to Intervene

Northern Pass Transmission LLC ) Docket PP-371
Application for Presidential Permit )
Pursuant to Rule 214 of the Federal Energy Regulatory Commission’s (“FERC”) Rules of
Practice (18 CFR 385.214), the Society for the Protection of New Hampshire Forests
moves to intervene in the above captioned proceeding.
1. Notices, correspondence and other communications
All notices, correspondence and other information concerning this proceeding
should be directed to:
Will Abbott
VP for Policy & Land Management
Society for the Protection of NH Forests
54 Portsmouth Street
Concord, NH 03301
Telephone: 603 224-9945, Ext 327
2. Movant’s Interest
The Forest Society is a private, non-profit membership organization established in
1901 with the mission to perpetuate the forests of New Hampshire through their
wise use and their complete reservation in places of special scenic beauty. The
Forest Society is a land conservation trust and forestry organization. As a land
trust we hold over 700 conservation easements statewide, permanently protecting
100,000 acres of New Hampshire’s landscape from further subdivision or
development. We also own 50,000 acres of land outright, in 170 reservations in
95 New Hampshire communities. As a forestry organization we actively manage
this land for forest products, public recreation, water conservation and wildlife
habitat. We have a long history of working with public and private landowners to
assure the health of New Hampshire forests and the integrity with which forestry
is practiced on these forested lands.
3. Movant’s Opposition
Our opposition to the Northern Pass project is based on the terrestrial impacts the
proposed power line corridor will have on the forests and natural resources of the
State of New Hampshire and the lack of any significant off-setting benefit to the
state, its environment, and its people. The preferred corridor identified in the
applicant’s Presidential Permit application raises seven core concerns to us:
1. The northern 45 miles proposed is new corridor through northwestern Coos
County, where extensive land conservation investments have been made over
the past 30 years and where the regional landscape is the foundation of the
region’s economy. We believe the proposed corridor and its elevated
structures will have negative impacts on these landscapes, including
destruction of important scenic values that are fundamental to the economy
and culture of the region and simply cannot be mitigated.
2. The 95 miles of corridor from Groveton, to Franklin (and then on to
Deerfield), which the applicant argues will largely be on existing power-line
rights of way, will require the expansion of some rights of way and the
installation of towers considerably higher in elevation than those presently on
the ground. We believe there is not enough information yet available to
ascertain the extent of the likely negative ecological and scenic impacts on
these landscapes, and we question whether they can be mitigated.
Consequently, the Forest Society advocates eliminating or minimizing the
construction of new transmission corridors through protected and/or presently
wild or undeveloped land in New Hampshire’s North Country, the White
Mountains, and other environmentally sensitive and scenic areas through
consideration of alternatives. Those alternatives could include a route along
existing transmission rights-of-way in the adjacent state of Vermont, and
through consideration of lowest-impact alternatives in New Hampshire.
3. There will be ecological impacts on the ground for the entire 140 miles of new
HVDC power line proposed for New Hampshire, which will need to be
thoroughly assessed before a determination is made that this new line is in the
public interest and that the preferred corridor represents the best of a broad
array of alternatives studied in detail.
4. In the New Hampshire municipalities impacted directly by the Northern Pass
project as proposed, 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. We have not yet been able to assess the
visual or ecological impacts on our own interests in land within the preferred
corridor. It is premature to determine the number of these conserved acres
that would be adversely impacted by the proposed project, but it is not too
early to suggest that some of these lands and the critical conservation values
for which they were protected would be permanently altered by the project in
ways that would violate existing conservation easements and reduce their
commensurate public benefit.
5. The preferred corridor proposes expansion of an existing power line corridor
through the White Mountain National Forest, which could significantly impact
the views people experience from nearby highways and hiking trails. We
believe that the multiple uses for which these lands were conserved in the
public interest do not include being a host for any new commercial power
projects, including 10 miles of new high elevation towers as proposed by the
Northern Pass.
6. The Northern Pass Project as proposed would be one of the largest
construction projects in the recent history of New Hampshire. New Hampshire
will bear the brunt of virtually all adverse environmental impacts of the
project, yet there seems to be little, if any, real long-term public benefit for
New Hampshire.
7. Given the scope of the proposed project and the significance of its impact on
New Hampshire’s forested landscape and its people, it is imperative that the
Department of Energy’s environmental review process is independent,
thorough, and free of any actual or apparent conflicts of interest. Furthermore,
we advocate that appropriate conditions to any permit that may be granted by
the Department of Energy protect the legitimate interests of the New
Hampshire public, the Forest Society and its members. Finally, the
Department of Energy’s EIS should provide appropriate responses to
any additional issues that may arise during the course of the permitting
For these reasons, the Forest Society respectfully requests that the Office of
Electricity Delivery and Energy Reliability of the United States Department of
Energy grant this motion to intervene.
4. Additional Comments
We will elaborate on the core concerns and desired outcomes in the scoping
process that US DOE hosts as part of its work in preparing a full Environmental
Impact Statement. We recommend that US DOE adopt rigorous standards of
review both for a determination of public interest for this project and for the
alternatives analysis which will be part of the EIS. We believe one alternative
that should be studied by the DOE EIS is one that follows existing power line
corridors from the Des Cantons station in Windsor, QUE all the way to Franklin,
NH. Not only is this the shortest distance between the two points, but it also
adheres to the applicant’s repeated reference in its Presidential Permit application
to the benefits and the preference of locating along existing corridors rather than
establishing new corridors.
We recommend that US DOE develop a scoping hearing schedule for its EIS that
includes hearings in the New Hampshire municipalities of Colebrook, Littleton,
Plymouth and Concord. We encourage DOE to provide a three month window of
time for these hearings, so that any and all members of the public who wish to
participate are afforded proper notice and opportunity. We also urge US DOE to
host through webinars or other Internet formats informational orientations to its
process in advance of the scoping hearings as part of the scoping process. There
is much confusion today within the State of New Hampshire over what the
process ahead is, how people can participate and how their participation and
comments will be used by US DOE in its decision-making on the Presidential
Permit. Just as it is up to the applicant to clearly identify the project goals and
objectives, it is up to US DOE to make every effort to educate the public on how
this decision will be made and how people can impact that decision.
Dated this 15th day of December, 2010.
Jane A. Difley, President/Forester
Society for the Protection of NH Forests
54 Portsmouth Street
Concord, New Hampshire 03301
Phone: 603 224-9945, Ext 321