Forest Society Written Comments Regarding Scope of EIS

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June 14, 2011
Mr. Brian Mills
Office of Electricity Delivery & Energy Reliability (OE-20)
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585
Dear Mr. Mills:
I write on behalf of the Society for the Protection of New Hampshire
Forests to offer comments on the scoping of the Environmental Impact
Statement concerning the application of the Northern Pass Transmission,
LLC for a Presidential Permit (OE Docket No. PP-371).
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 30 years.
The Forest Society owns and manages 170 forest reservations in 96 New
Hampshire communities, permanently conserving 50,000 acres of
working forest land. 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 and 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
31 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
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It is for these reasons we filed for intervener status last December, in response to your
November 16, 2010 invitation posted in the Federal Register.
As the public discussion of the Northern Pass project has unfolded since our petition as
an intervener was granted by DOE, it has become clear that Northern Pass is part of a
larger strategic plan by Hydro-Quebec to export more than 4,700 MW of electricity to the
United States over the next 25 years. Further, other Canadian utilities are working on
projects to export electricity to northeastern United States. These strategic plans by
Canadian utilities provided the foundation for a petition submitted to DOE on April 28,
2011 by the Conservation Law Foundation (and a number of other conservation
organizations including the Forest Society) to ask DOE to conduct a comprehensive EIS
on the larger set of issues posed by these prospective sales of electricity across the
International Border. It is far better to look holistically at options for bringing such power
to market than to look at each separate project one at a time. Our view is that such a
comprehensive analysis by DOE will inform the specific choice of alternatives to study in
the Northern Pass EIS, and, therefore, should be undertaken specifically with such a
goal in mind.
Given the significant impact the Northern Pass project as proposed would have on 180
miles of New Hampshire landscapes, we believe that DOE must start its National
Environmental Policy Act analysis in the EIS with a clear determination that there is a
public need for this project and that the public interest is clearly served by moving the
project forward. If you find there is no such clear public interest served, we urge you to
deny the Presidential Permit.
Many questions were raised about the public benefits of this project by the more than
300 speakers (among 2500 attendees) at your March 2011 scoping hearings in New
Hampshire and by the many citizens who have commented since then. The answers to
some of these questions have a direct bearing on whether the project as proposed
actually serves the larger public interest. We recommend that your public benefits
analysis address at least these issues:
• The applicant suggests by virtue of submitting its application that the
electricity provided by the project is needed. Is the electricity proposed
to be imported from Hydro Quebec needed in New Hampshire or New
England, based on current consumption and demand? If there is no
immediate need, by what analysis is there determined to be a future
need, and when does that need become sufficiently urgent to plan for it
outside the existing New England Forward Capacity Market?
• The applicant claims that this power will be competitively priced. What
are the measurable benefits to New England and New Hampshire
electricity consumers of the project as proposed, and how do these
benefits compare with the private benefits to be received by the project
applicant if the project were to be built as proposed?
• The applicant claims that the project will provide “low-carbon” power. Is
there a clear greenhouse gas (GHG) benefit to this project when a full
analysis and accounting is done for all GHG debits and credits on both
sides of the border? Has there been a clear demonstration that the
construction of this new power line will in fact result in reduced
combustion of fossil fuels in New England, given current and future
market conditions?
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• The applicant claims that the project will provide reliable hydro-electric
power to New England. Is there any analysis documenting the capacity
and reliability of Mother Nature to provide the water quantity needed to
generate the electricity promised over the 40 year life of the project in
addition to 1) the projected needs of the Province of Quebec over the
same time frame and 2) all other legally contracted exports presently in
In determining which alternatives to study in the EIS, we believe that DOE should
establish a broad range of alternatives and a rigorous threshold for analysis of each
alternative. We urge you to include a comprehensive analysis of at least four options, in
addition to the preferred alternative submitted by the applicant:
1. The “No Action” Alternative
Required by law, the “no action” alternative is intended to tell the story of
what happens if the project is not built at all. In the case of the Northern Pass
project this should include more than simply an assessment of the negative
environmental impacts forgone. This alternative should include a structured
analysis of the New England energy market without Northern Pass --- a full
review of the economic and environmental impacts of not building the project.
If the EIS is to offer a full picture of the “No Action” alternative, it should be
clear from your analysis that a full accounting of how the New England region
plans to meet its future energy needs without Northern Pass has been
2. The Vermont/New Hampshire Existing Corridor Alternative
If National Grid’s existing 2000 MW HVDC corridor, which enters Vermont at
the Town of Norton, crosses into New Hampshire on the Upper Connecticut
River, and ends at the Sandy Point Substation in Groton and Ayer,
Massachusetts, could be upgraded within the existing corridor to host a single
3200 MW line clearly the environmental benefits of using an existing corridor
instead of cutting an entirely new swath through 45 miles of un-fragmented
forests, family farms, homes, recreation lands, and legally protected
conservation areas would be self evident. The environmental disturbances
along the existing rights-of-way in the preferred Northern Pass corridor would
also be avoided. According to public statements by the applicant, it has to
date declined even to approach the State of Vermont and National Grid to
explore this alternative. DOE should fully exhaust any and all
reconfigurations of the current right-of-way for the existing 2000 MW HVCD
line as one alternative in its EIS.
3. A Burial Alternative
Advocates for Northern Pass have repeatedly stated publicly that burying the
Northern Pass would “be at least ten times more expensive” than putting the
power lines above ground as proposed. DOE should test this claim in the
EIS. It should select a viable corridor along an existing transportation rightof-
way (where the earth has already been disturbed) and assess what the
true cost of burial to current industry standards would be. The goal of the EIS
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is to identify the least damaging environmental alternative. While burial may
require more cost up front, it may be the most socially and environmentally
desirable alternative. At today’s wholesale electricity price in New England,
total revenues to Hydro Quebec over the 40 year life of this project will be
over $50 billion. Before ruling out a burial option, should we not at least
explore what the actual cost would be? At least one DOE option should
explore a burial alternative.
4. A New York Alternative
The EIS should also carefully examine alternatives that directly import 1200
MW of electricity to the New York grid. For the past four years ISO-NE has
sold up to 5% of its total annual generation of electricity to ISO-New York.
There is clearly a more immediate need for this 1200 MW in New York than in
New England. The Champlain Hudson Express project was originally scaled
to import 2000 MW of Canadian electricity, then more recently reduced to
1000 MW (reportedly for lack of market need in Southern New England). If
this project could be a conduit for the 1000 MW it is currently budgeted for
plus the 1200 MW proposed to be imported over the Northern Pass project,
there would clearly be an environmental benefit and an economic benefit.
The environmental benefit is that New Hampshire’s landscape would not
have to be affected at all. The economic benefit is that this new 2200 MW
facility would deliver the power to markets where there is in fact a current
The DOE Notice of Intent published on February 11, 2011 identified 18 specific sets of
resources that will be addressed for each alternative studied. We believe this list is a
good start. You received many comments expanding this list and offering detailed
recommendations for your research and analysis of each resource area. We add the
following specific recommendations:
1. Require the creation of the best visual impact analysis that current technology
can provide for every above ground mile of every alternative studied. The
public needs to visualize the impacts of each alternative studied, and the final
DOE decision on the Presidential Permit application needs to address this
issue thoroughly. For the 31 New Hampshire communities impacted by the
project as proposed, for the White Mountain National Forest and for those
millions of visitors a year to New Hampshire who choose to recreate in areas
where these new towers would be erected, this landscape scarring is one of
the most significant negative impacts of the proposed project.
2. Complete a detailed analysis of the impact of each alternative on the
conservation values of lands protected by the federal government (the White
Mountain National Forest and the National Park Service), the state
government (state forests and parks), municipal governments (town forests
and open space) and private non-profit land trusts (like the Forest Society).
Two core conservation values at issue are the views of the conserved
property and the views from the conserved property.
3. Complete a rigorous socio-economic analysis of each alternative, including a
thorough discussion of how the proposed alternative would affect real
property values, local and regional tourism economies and the potential to
expand and develop local and regional alternative energy projects.
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4. Fully explore the impact of each alternative on forest and habitat
fragmentation, specifically as it relates to sensitive areas identified by the
New Hampshire Fish & Game Department’s Wildlife Action Plan.
5. Clearly articulate and discuss the impacts of proposed structures on riparian
zones, wetlands and other sensitive natural communities.
6. Fully review the current science on two potential health impacts of overhead
HVDC transmission lines: 1) the impact of Electro Magnetic Forces on people
and animals and 2) the impact of chemical treatments to control vegetation
growth within the rights-of-way on people, animals and plants.
We have three final suggestions:
First, the applicant has suggested that it plans to file an application to the New
Hampshire Site Evaluation Committee upon the DOE publication of a Draft
Environmental Impact Statement. Clearly, your work on this EIS will be an important
resource to the NH SEC in its permitting role. We strongly encourage you to reach out
to the Chairman of the NH SEC as you determine which alternatives to study to assure
that the information needs of federal and state decision-makers are served by your
research and analysis.
Second, since the filing of its Presidential Permit application in October 2010, Northern
Pass has formally amended its application at least three times. We respectfully
recommend that DOE not entertain any further amendments to the original application
after today. The preferred alternative of record submitted by the applicant as of today
should be the applicant’s proposed alternative studied in the EIS. If the applicant
requests further amendments to its original application, we suggest that DOE re-set the
clock on the NEPA process for the Northern Pass project, and start this process over.
Finally, we believe that when DOE issues its final record of decision for this application,
it should be self evident that this is the best informed record of decision that has ever
been issued by the Department of Energy for a Presidential Permit. To meet the letter
and spirit of the National Environmental Policy Act as they relate to this application, the
Forest Society stands prepared to assist you where we can.
Jane A. Difley