June 19, 2015
Commissioner Van McLeod
New Hampshire Department of Cultural Resources
20 Park Street
Concord, NH 03301
Dear Commissioner McLeod:
On June 10 we attended a work session hosted by the New Hampshire Division of Historic
Resources to update cooperating partners and other stakeholders on the progress of the US
Department of Energy’s consultants in assessing the impact of the proposed Northern Pass
project on New Hampshire’s historic resources. As consulting parties to the federal Section
106 process, we are writing to express our deep frustration with this process, and to strongly
urge you and your Department to set a higher bar for how New Hampshire’s historic landscapes
and other cultural resources are treated in the forthcoming state regulatory review process for
Northern Pass established in RSA 162:H.
While we believe that NH DHR staff are raising some good and relevant questions in their own
analysis of the work DOE contractors are doing on the Section 106 review, we are dismayed
that NH DHR agreed to the federal decision to limit the study area (referred to as the “Area of
Potential Effect”) to one mile on either side of the proposed centerline for the proposed
Northern Pass power line. The most significant historic resources of central and northern New
Hampshire are the landscapes which are home to tens of thousands of residents and which
attract millions of visitors annually from around the world. By limiting the scope of the federal
review to one mile on either side of Northern Pass’s proposed overhead power line, the federal
government is treating these assets at best as if they are non‐existent and at worst as if they
are worthless. New Hampshire deserves better.
We trust that under your leadership the Department of Cultural Resources will provide
the New Hampshire Site Evaluation Committee
with a comprehensive assessment of the rich history of these landscapes if and when the SEC
considers an application from the Northern Pass project that proposes to scar these landscapes.
As one example, we would encourage you to look at the impact Northern Pass as proposed will
have on several distinct views from the Appalachian National Scenic Trail and other historic
trails to the peaks of New Hampshire’s 4000 footers. Many of these historic landscapes as
viewed from hiking trails are outside the one mile APE. Other similar large scale transmission
projects have used APE’s well beyond one mile on either side of the proposed project
centerline.
A second concern we have as consulting parties to the federal Section 106 process is the lack of
transparency of the process itself. We understand that there are some archeological resources
that deserve to have a layer of confidentiality to protect their location on (and in) the ground.
However, the public also deserves a full and open discussion of how historic resources will be
conserved when development projects on the scale of Northern Pass are proposed.
We believe the review process in this instance should err on the side of too much sunshine, not
on the side of too little. To date, the historic resource impacts of the Northern Pass project are
primarily discussed only behind closed doors, with limited public access to documents and
opportunity for review. New Hampshire deserves better. We trust that under your leadership
the State of New Hampshire’s regulatory review of Northern Pass impacts on our cultural
resources will include a very robust and very public discussion to properly and fully inform SEC
decision‐makers. It is imperative that non‐sensitive documents be made available online for
public scrutiny.
A third concern we would like to share with you concerning the federal Section 106 review
process is the frustration of watching the important issue of cultural resources being
segregated from the environmental review that the federal government conducts under the
National Environmental Policy Act. It appears that the federal regulatory review process treats
cultural resources separately from environmental issues, almost as if cultural resources are an
afterthought. These federal reviews occur on two separate, parallel tracks. The problem is that
natural and historic resources share the same ground. They are part of one larger whole. We
trust that under your leadership the decision‐makers at the NH SEC will receive information
from your Department that fully and accurately depicts how the Northern Pass project as
currently proposed impacts the common ground that cultural and natural resources share. For
example, many historic sites in New Hampshire’s White Mountain region are historic because
of the exceptional views of the mountains from them. Protecting the sites without protecting
the views from the sites perfectly illustrates the dictionary definition of “myopia.”
We write this letter because we believe the federal review process of historic and cultural resources
as it relates to the Northern Pass application for a federal Presidential Permit is failing
New Hampshire. But it is not too late for your Department to assure that the state regulatory
review process conducted by the NH Site Evaluation Committee does not also fail New Hampshire and
some of its most treasured and long-honored cultural assets. We encourage you to set a high bar for this state
review, and to assure New Hampshire citizens that the extraordinary landscapes we live with daily and
that we market worldwide remain part of the legacy we leave to future generations of Granite State residents
and visitors.
Sincerely,
Will Abbott, wabbott@forestsociety.org
Society for the Protection of NH Forests, 54 Portsmouth Street, Concord, NH 03301
Susan Arnold, sarnold@outdoors.org
Appalachian Mountain Club, 5 Joy Street, Boston MA 02108
Doug Evelyn, Sugar Hill, NH, develyn1@myfairpoint.net
53 Old Post Road, PO Box 579, Sugar Hill, NH 03586
Carl Martland, Martland@mit.edu
Nancy Martland, nancy.martland@gmail.com
16 Post Road, Sugar Hill 03586
Kris Pastoriza, krispastoriza@gmail.com
294 Gibson Rd., Easton, NH 03580
Susan Schibanoff, susan.schibanoff@unh.edu
162 Loop Road, Easton NH 03580
cc: Governor Maggie Hassan
Meredith Hatfield, Director, NH Office of Energy & Planning