SPNHF EIS Scoping Hearing Comments by Jane Difley Concord, NH Sept. 23, 2013

Jane Difley/SPNHF EIS Scoping Hearing Comments Sept. 23, 2013 Concord, NH

My name is Jane Difley, President/Forester of the Society for the Protection of New Hampshire Forests. We were founded more than a century ago to perpetuate the forests of New Hampshire through their wise use and complete reservation in places of special scenic beauty. Today, New Hampshire can still claim to have many such places.

The Forest Society filed as an intervener in opposition to the original Northern Pass application, and we remain opposed to the Northern Pass application as amended.

I testified at Department of Energy’s original scoping hearings, and the Forest Society filed detailed scoping comments on June 14, 2011.  We stand by our original Environmental Impact Statement recommendations. Tonight, we would like to additionally suggest that the DOE thoroughly study multiple alternatives that would completely bury the Northern Pass transmission line.

We believe that since the applicant has neglected to do any comprehensive analysis of burial alternatives, the DOE must do it for them in order to ensure that any decisions that are made do not unnecessarily harm our natural environment. The National Environmental Policy Act requires no less.

We would ask you to include engineering studies that document the true costs of using the latest technologies to completely bury the transmission line in at least two different corridors.

NEPA also requires that the EIS study the “no-build” alternative.  We believe that DOE should examine whether the societal investment of $1.4 billion could be better spent on energy conservation measures and forms of home-grown electricity generation closer to consumers in southern New England than James Bay.

We further believe that before the review process begins, DOE should voluntarily create a process to allow for public input on the alternatives you choose to study as part of the Northern Pass EIS.  In our view, DOE can build public trust and confidence in a completed EIS by asking the public whether you are studying the right alternatives before you begin.

As Governor Maggie Hassan noted in her recent editorial in the Boston Globe--and I commend her on her comments--the Northern Pass project as proposed is “all costs and few, if any, savings for the people of New Hampshire.” In its inadequate analysis, Northern Pass fails to account for the cost of damaging New Hampshire’s landscapes, including the White Mountain National Forest, other conserved lands, and private properties. Northern Pass has claimed that it is “too expensive” to bury its transmission line; on the contrary, we maintain that for New Hampshire it is far too expensive not to bury it.

If the additional electricity that Hydro Quebec proposes to export to New England is ever needed for the public’s benefit--a conclusion we believe Northern Pass has failed to establish--then the project should only be built if it is buried in its entirety. New Hampshire and New England deserve no less. To this end, DOE should thoroughly assess every burial alternative that exists.