POST-HEARING MEMORANDUM OF NON-GOVERNMENTAL ORGANIZATION (“NGO”) INTERVENORS
The following is the Summary of Argument from the NGO Intervenors at the New Hampshire Site Evaluation Committee Proceedings Concerning Northern Pass
POST-HEARING MEMORANDUM OF NON-GOVERNMENTAL ORGANIZATION (“NGO”) INTERVENORS
AMMONOOSUC CONSERVATION TRUST APPALACHIAN MOUNTAIN CLUB AND CONSERVATION LAW FOUNDATION
The project proposed by Northern Pass Transmission LLC and Public Service Company
of New Hampshire d/b/a Eversource Energy (jointly, “Applicants”) would change the character,
landscapes, and environment of New Hampshire forever and bring few if any benefits to the
state. A petition for certification must demonstrate by a preponderance of the evidence1
that the proposed project would not have unreasonable adverse effects or unduly interfere with the
orderly development of the region, and is in the public interest.
To the contrary, the Project as proposed fails each of these tests.
The 192-mile project proposed in this proceeding would traverse the entire state of New
Hampshire, imposing adverse impacts on a scale that New Hampshire has never seen before
from a single energy project. Credible evidence adduced by Counsel for the Public, Society for
the Protection of New Hampshire Forests (SPNHF), Appalachian Mountain Club (AMC) and
numerous other Intervenors, as well as thousands of New Hampshire residents and others via
written comments and oral testimony, establishes that the Applicants have both grossly
undercounted and undervalued the scenic resources that will be affected by the Project and
grossly understated the Project’s impacts on aesthetics, communities, and the environment.
The Applicants attempt to downplay the massive scale of impacts throughout the length
of the state, and instead of addressing or mitigating those impacts, they offer a red herring – they
claim that the state will reap benefits in terms of capacity market price reductions and
greenhouse gas emissions reductions. As this memorandum demonstrates, together with the
memoranda and exhibits of Counsel for the Public and the New England Power Generators
Site 202.19. See also 102.37. 2
NH RSA 162-H:16; Site 301.14-16.
Association (NEPGA), these so-called benefits do not exist and should not be accorded value by
the Committee as a counter-weight to the heavy adverse burden of this project.
In petitioning their case for the so-called “Northern Pass” project, the Applicants have
failed to meet their burden of demonstrating that construction and operation of the Project will
not have an unreasonable adverse effect on the natural environment. The Project would
seriously degrade two exemplary rare natural community occurrences and create severe forest
fragmentation by construction of 32 miles of new powerline right-of-way through some of New
Hampshire’s most extensive unfragmented forest. The Project will diminish the state’s native
biodiversity and permanently reduce the extent of interior forest habitat in the North Country,
and have a severe and long-lasting unreasonable adverse effect on the state’s natural
environment.
The Applicants have failed to meet their burden of demonstrating that the Project will not
unduly interfere with the orderly development of the region. The regional capacity market and
greenhouse gas impacts alleged by the Applicants have been disproven and fail to establish
benefits to employment or the economy. On the contrary, if completed the project would likely
have negative impacts on the orderly development of the region by displacing or deferring the
development of local clean energy resources. In addition, the proposed decommissioning plan
fails to comply with Site 301.08(d)(2)b.
And the Applicants have overwhelmingly failed to meet their burden of demonstrating
that the Project is in the public interest with regard, inter alia, to the welfare of the population,
air and water quality, or the overall economic growth of the state. By offering no more than an
unsubstantiated red herring—the false promise of capacity market price benefits and greenhouse
gas reductions that are not documented and will never materialize—the Applicants hope to tempt
the state to make a bad deal. Ultimately, the cumulative negative effects of the Project lead to
the conclusion that the Project is not in the public interest.
The Committee should reject this bad deal for New Hampshire.