AMC Comments to SEC on Northern Pass March 14, 2014

Susan Arnold, Appalachian Mountain Club

Northern Pass Comments to the NH SEC

March 14, 2016 –Plymouth, NH

My name is Susan Arnold and I am Vice President for Conservation at the Appalachian Mountain Club.  The AMC is the oldest conservation and recreation organization in the country, with more than 100,000 members and supporters from Maine to Washington, DC, including more than 12,000 here in New Hampshire.  In our 140 year history, AMC has helped to protect this region’s open spaces, including from poorly sited energy projects such as Northern Pass, which is requesting to use high impact, old technologies to maximize profits at the expense of NH’s iconic landscape. It is that unnecessary impact that has brought out so many people in opposition to this project as proposed. And the choice is not Northern Pass or nothing, or Northern Pass versus expensive energy. Many other projects recently placed bids in the New England Clean Energy RFP, including Hydro-Quebec with another transmission partner that uses complete burial.

Tonight I will make the following three points:

1.  SEC Site visits. AMC appreciates that the SEC has stated its intention to host additional public meetings and site visits, based on the concerns expressed by many relative to recent and upcoming site visits: minimal public notice, time of year selected, and overlap with town meetings.  Our observations from these site visits, including today’s, is that the stop locations and vantage points are those principally selected by the Applicants’ visual consultant for his photo simulations, which reflect a bias towards minimizing visual impacts, whereas other, more egregious locations were downplayed or ignored.

As an example from last week’s site visit in Stark, the Rte 110 location photo simulation by DeWan is shown in the top picture (see attached). Yet where the line would cross Route 110, a scenic byway, there is a much more serious visual impact, but this view (lower picture) was not photo-simulated by the Applicants’ consultant. We urge you to consider site visits to locations suggested by parties other than the Joint Applicants, to host them with sufficient advance notice, and during seasons when the most people – resident and non-resident -- would see and experience the impacts. For example, even a novice real estate agent knows that now, during mud season, is the least desirable time in which to show properties and their landscape settings.

2.  The Applicant’s Forward NH Plan is a façade. The SEC rules require the use of best practical measures to avoid, minimize, or mitigate project impacts. With its proposed 60 miles of burial, Northern Pass has about 1/3 of the “avoid and minimize” right. Bury the rest and this commitment is met, similar to how other HVDC lines are now proceeding in the region and elsewhere.

But the mitigation portion – the so called Forward NH Plan-- is a façade.  Starting with hearings last fall and ramping up even now, the Applicant has promoted its Forward NH Plan as the panacea to provide direct benefits to New Hampshire.  In reality it is a self-serving business fund. “No strings” attached Les Otten is the latest. Untold is that Otten needs BayRoot’s lands for his Balsams project, Bayroot wants this transmission line on their lands for multiple business reasons, Otten needs investment money, and Northern Pass is desperate for public support. The strings are very much attached.

Northern Pass only submitted a skeleton of the Forward NH Plan in its application for good reason. It is not a mitigation fund designed to deal with Project impacts or actually benefit NH. It is primarily a slush fund to enable Northern Pass to direct funding to where it most needs to bolster support.  While the training of young lineman is noble, it’s important to remember that with energy deregulation utilities cut their linemen training programs and they are now reaping the fruits of that short sightedness and experiencing a lineman shortage, since many are aging out of the workforce. Mitigation plans and funds should be transparent, and directly address the project’s actual impacts. The Forward NH Plan is designed by the Applicant for the promotion of the project through the calculated dispersal of funding to bolster its own business interests. Until such time that the public has sufficient information to accurately scrutinize the claims for this plan, the Forward NH Plan should not be considered in the Application review process.

3.  The AMC strongly objects to all the waiver requests submitted by the Joint Applicants, but especially the request on decommissioning. To avoid providing a required decommissioning plan and funding in its SEC Application, the Joint Applicants are requesting a waiver, arguing that this transmission line may never be removed—underscoring the permanence of the scar this project will inflict on NH’s landscape if approved as proposed. Their argument ignores the fact that an HVDC transmission line is very specialized, with minimal “on and off” ramp capabilities for power to join and or be taken from it. Hydro-Québec is a government-owned public utility. Should the people of the Province of Quebec determine in the future that their domestic power needs require additional power, or Hydro-Quebec power becomes non-competitive in the NE-ISO market, this line could become outdated.  And given the current rapid evolution of the energy sector, including transmission and generation, this transmission line could become unnecessary in the future. The joint Applicants’ assumption that this power will be needed and competitive far into the future is nothing more than unsubstantiated conjecture.

One of the Joint Applicants, Public Service Company of New Hampshire (PSNH), has a recent history of not removing decomissioned transmission poles.  When a portion of the line from North Woodstock through Lincoln, Easton, and Sugar Hill was upgraded, the old 215 pentachlorophenol and creosote soaked poles were dumped in the ROW near the Reel Brook Trail, a feeder trail  to the Appalachian National Scenic Trail in White Mountain National Forest. The Town of Easton filed numerous complaints with the State about this dumping, but not until this Application came forward were those poles suddenly removed. Many of the poles’ stubs remain in standing water.  This callous disregard for the impacts of this dumping—in the White Mountain National Forest and vicinity of the AT no less!—underscores why this request for a waiver of the decommissioning requirements in the SEC rules must be denied. The revised SEC rules were designed to make decommissioning promises a reality, and not leave New Hampshire with the Hobson’s choice of a permanently-scarred landscape or a tax-payer funded bailout.

Thank you for your time and consideration.