courtesy Society for Protection of New Hampshire Forests

Last week brought a fitting capstone to the botched year-long rollout of the Northern Pass project.  In a disturbing turn of events, the project developers sought to scuttle a historic plan to preserve a storied wilderness in New Hampshire’s North Country. Their attempt failed, but what the episode says about their future tactics is anything but encouraging for New Hampshire and the region.

Northern Pass Transmission, LLC (NPT) – a partnership between Northeast Utilities and NSTAR – has spent 2011:

• misrepresenting the Northern Pass project’s environmental benefits,
• misleading the public about potential savings to New Hampshire electric ratepayers,
• withdrawing and refusing to analyze alternatives (including options that would avoid overhead lines through the White Mountain National Forest),
• blocking a full assessment of the nature and extent of the region’s need for more electricity imports from Canada, and
• trying to buy off landowners along the northernmost 40 miles of the project.

It has been clear for some time that the current proposal is really about two things – securing profits for Hydro-Québec and propping up NU subsidiary PSNH’s weakening bottom line. CLF is not alone in wondering: what’s in it for New Hampshire?

Last week was a vivid preview. And if you care about New Hampshire’s iconic wilderness landscapes or the organizations that protect them, it’s not a pretty picture.

Earlier this fall, we learned that NPT was bidding to purchase a strip of land through one of the North Country’s crown jewels – the magnificent Balsams estate in Dixville Notch – from its owner, the Neil Tillotson Trust.

Enter the Society for the Protection of New Hampshire Forests (SPNHF), a key collaborator with CLF on Northern Pass advocacy and one of the state’s leading land conservation organizations. Culminating a decade of effort to preserve the Balsams landscape, SPNHF secured from the Trust a conservation easement over 5,800 acres of spectacular wilderness surrounding the resort, provided that SPNHF raises $850,000 for the easement by mid-January. (You can follow the effort here. Word is that, as of today, SPNHF is nearly a third of the way there.) The easement would preclude any transmission corridor.

The land is an ecological and scenic marvel, and the deal marks a historic land preservation achievement for SPNHF, the Trust, and New Hampshire as a whole.

The Balsams Resort in winter (photo credit: j-fi/flickr)

NPT’s bizarre and audacious response: launch a legal attack on the conservation plan.

Last week, NPT asked the state Attorney General’s Office to disapprove the easement on the ground that NPT’s earlier bid was higher. Then on Friday of last week, NPT made a very public offer to buy both the transmission corridor and the conservation easement, which would secure a right to site the Northern Pass project on the Balsams property. The last move was particularly odd because most bidding wars don’t involve publicly bullying a seller – a respected charitable trust no less – into accepting an offer.

As noted in the Concord Monitor and on NHPR, news came late Friday afternoon that the state Attorney General’s Office had approved the sale of the conservation easement to SPNHF, despite NPT’s objections and richer offers. The approval letter noted that it was well within the Trust’s charitable purposes and discretion to sell the easement to SPNHF for less than NPT’s offer. In other words, the Trust should be free to decide that preserving the Balsams property for the benefit of the North Country is more important than the Trust’s financial return.

Why was NPT’s attack on the conservation plan so troubling?

• NPT sought to undermine land preservation efforts throughout New Hampshire. Land preservation almost always requires generosity – the landowner’s decision to accept less than market value or to make an outright donation of an easement. If it had been successful, NPT’s legal attack would have left no room for such generosity, granting any private developer the power to block a landowning non-profit’s preservation of its land whenever the developer offered more money than the conservation organization or community that would hold the conservation easement.
• NPT is on war footing.  NPT is pursuing the equivalent of scorched earth litigation, resorting to strong-arm tactics and legal appeals to the state, including a threat of litigation to block the SPNHF easement that, as of today, remains on the table. At this early stage of the project’s permitting, this is exactly the opposite of what we need – a well-informed regional and statewide dialogue about our energy future, the project’s potential role if any, and the alternatives to traditional overhead lines along NPT’s proposed route.
• NPT has broken its promise to find a route “that has support of property owners.”  The Trust made a decision not to sell to NPT; within days, NPT was crying foul to a state official.  NPT’s appeal to the state reveals, for all to see, that NPT will respect the will of landowners only when that will is to sell NPT the land it wants. As others pointed out before the Attorney General Office’s decision, NPT’s carefully-worded disinterest in using eminent domain (except as a “very last resort,” in the words of PSNH President Gary Long) is no longer credible, if it ever was.
• NPT is willing to spend huge sums, but only to get the project it wants. Without hesitation or public discussion, NPT offered what amounts to a $1 million donation (of Hydro-Québec’s money) to the Trust, including a $200,000 grant to Colebrook Hospital and the money for the Balsams conservation easement. Clearly, NPT is willing to spend millions above and beyond market costs to get the route it wants, even as it rejects as too costly alternatives that could be better for New Hampshire.

Above all, the Balsams episode shows that NPT is not pursuing the Northern Pass proposal as a public-minded enterprise for the “good of all of New Hampshire.” With so much at stake for the region and New Hampshire, CLF’s work of 2012 is to secure a searching and rigorous public review process that will scrutinize every element of the Northern Pass project and ensure that the public interest – and not the dollars in NPT’s coffers – determines the project’s fate.

For more information about Northern Pass, sign-up for our monthly newsletter Northern Pass Wire, visit CLF’s Northern Pass Information Center (http://www.clf.org/northernpass), and take a look at our prior Northern Pass posts on CLF Scoop.

photo credit: Witthaya Phonsawat

With the Northern Pass project on the table, as well as other looming projects and initiatives to increase New England’s imports of Canadian hydroelectric power, the region’s energy future is coming to a crossroads. The choice to rely on new imports will have consequences that endure for decades, so it’s critical the region use the best possible data and analysis to weigh the public costs and benefits of going down this road. To date, there have been almost no objective, professional assessments of the ramifications.

Today, CLF is making available to the public a technical report prepared by Synapse Energy Economics addressing a crucial issue: the potential effects of new imports on the region’s own renewable power industry. 

The report, Renewable Portfolio Standards and Requirements (PDF), explains how the Renewable Portfolio Standards (RPS) of each New England state and New York address hydropower and then examines the potential effects of allowing Canadian large-scale hydropower to qualify for incentives by allowing such power to count toward states’ goals for renewable power under RPS programs.

Vermont is currently the only state that allows Canadian hydropower to qualify for its (now voluntary) RPS. If Vermont elects to use Canadian hydropower to fulfill all or most of its RPS goal (which is contemplated by pending legislation that would make Vermont’s RPS mandatory), there would be a modest but important reduction in the incentives available to new renewable projects in the region. The report concludes that there would be a much more significant impact if the RPS programs in other states were changed to allow Canadian hydropower to qualify (as was proposed in New Hampshire and Connecticut earlier this year and is being discussed right now in Massachusetts). In that scenario, imports from Northern Pass (or import projects of similar size) would swamp the market, taking up 45% of the region’s mandate for new renewable power and deeply undermining the viability of new renewable development in the Northeast.

This finding is a new illustration of why CLF opposes changing RPS laws to count large-scale hydropower toward the region’s renewable goals, a result that would both harm local renewable projects and send incentives funded by New England ratepayers out of the country to suppliers that do not need them.

For their part, Northern Pass’s developers have downplayed any risks to local renewable energy but have refused to refrain from lobbying for and securing the very changes to the RPS laws that Synapse predicts would, when paired with new imports through Northern Pass, cut the legs out from under renewable energy based in New England. It is no wonder that it’s not only CLF sounding the alarm on this issue:  electric industry veterans like Cynthia Arcate and the trade association of New England’s competitive electric generating companies have also expressed concern.

The bottom line for CLF: any plan to increase imports will need a robust and comprehensive set of enforceable commitments – which are completely absent in the current Northern Pass proposal – for the region to ensure that New England’s own renewable energy industry will prosper and grow into the future. 

For more information about Northern Pass, sign-up for our monthly newsletter Northern Pass Wire, visit CLF’s Northern Pass Information Center (http://www.clf.org/northernpass), and take a look at our prior Northern Pass posts on CLF Scoop.

photo credit: flickr/OpenThreads

The Northern Pass transmission project is being pitched by its developers as a clean energy proposal for New Hampshire. As I’ve pointed out before, Northern Pass is a regional proposal with dubious benefits in the Granite State. Unfortunately, the developers’ hollow promises have found an audience further south, in Massachusetts.

From the public discussion as well as the developers’ PR blitz, you might think that the Northern Pass – a high voltage transmission line that would extend 180 miles from the New Hampshire-Canada border, through the White Mountains, to Deerfield, New Hampshire – is just a New Hampshire issue. It’s not: the ramifications of this project extend well beyond New Hampshire.  The implications are both regional and enduring, as they will shape the energy future of New England for decades to come.

Given this context, the U.S. Department of Energy (DOE) should be leading a pro-active, regional assessment of the options for additional imports of hydroelectric power from Canada. So far, DOE has squandered its opportunity to lead such an assessment while the Northern Pass permitting process remains on indefinite hold. Since April of this year, CLF has been urging the DOE to use this delay to deliver a fair, big picture review of the Northern Pass. It’s what New England deserves, and what DOE owes the public.

Although you wouldn’t know it from the media or the developers’ “MyNewHampshire” advertising campaign, Northern Pass also is a Massachusetts issue. Why? As if hidden in plain view, it’s at the center of Massachusetts’s plan to combat climate change. You might say it’s the elephant in the room.

Massachusetts’s 2010 “Clean Energy and Climate Plan for 2020” (the Plan) seeks to reduce Massachusetts’s greenhouse gas emissions (GHG) 25% below 1990 levels by 2020. CLF has applauded the Plan as an aggressive, nation-leading effort. However, we long have been dubious of the Plan’s reliance on potential imports of Canadian hydropower.

Regrettably, the final Plan (at pp. 45-46) uncritically bought the Northern Pass developers’ line that Northern Pass will reduce greenhouse gas emissions by 5.1 million metric tons annually by 2020. Where does the Plan get that figure? The figure was never publicly vetted or discussed during the public planning process in which CLF was an active participant. The only citations are to the developers’ website and to a 2010 report by an energy consulting firm hired by the developers. That’s it. Massachusetts is taking the developers’ sales pitch at face value.

The Plan goes on to claim that Massachusetts can take credit for the entire reduction, even though the current Northern Pass proposal, by design, does not guarantee that Massachusetts customers will purchase any hydropower from Hydro-Québec through Northern Pass or otherwise. So, just how much of Massachusetts’s ambitious GHG reduction goal does Northern Pass’s supposed 5 million tons represent? More than 70% of the Plan’s reduction goal for the electric sector and more than 20% of the Plan’s goal overall. Of the Plan’s “portfolio” of initiatives, the Plan credits Northern Pass with achieving the single highest amount of emissions reductions.

Northern Pass is a highly questionable element of the Plan for a number of reasons. First, it’s not clear how much power Massachusetts will actually get from Northern Pass. Second, the project faces myriad permitting hurdles and isn’t anywhere close to a done deal. Third, Massachusetts has no direct role in the project’s development.

But it’s worse than that. The report by the developers’ consultant – and its 5.1 million ton estimate of Northern Pass’s reductions of GHG emissions – is simply wrong. The report’s error is a contagion that directly undermines the Plan’s ambitious GHG reduction goal.

To make a long story short, the report assumes that Canadian hydropower results in no GHG emissions. That assumption is contradicted by Hydro-Québec’s own field research on the GHG emissions from the recently constructed Eastmain reservoir – the very reservoir where, according to testimony by a developer executive, Northern Pass’s power will be generated.  Together with other scientific literature, the research demonstrates that reservoirs have long-term, non-zero net GHG emissions (in part because they permanently eliminate important carbon “sinks” that absorb carbon dioxide from the atmosphere, such as boreal forests). That makes the  5 million tons, at a minimum, blatantly inflated.

But even more importantly for Northern Pass and Massachusetts’s GHG reduction goal, the same research suggests that Northern Pass may not reduce GHG emissions at all before 2020, if ever. According to Hydro-Québec, a newly inundated reservoir has GHG emissions comparable to a modern natural gas power plant in the decade following flooding.  This chart from a Hydro-Québec paper, which itself likely underestimates reservoir emissions over time, tells the tale:

Natural gas plant and reservoir (Eastmain 1) emissions are similar in first decade of reservoir operation

And according to the developers’ projections, Northern Pass would overwhelmingly displace natural gas-fired generation (itself a missed opportunity to displace the output of coal-fired power plants).  If Northern Pass relies on new hydroelectric facilities in Canada for its power (as the developers and their consultant are assuming), Northern Pass as proposed will have no net effect on emissions in its early years and may never result in meaningful reductions, let alone 5 million tons per year.

Without the claimed reductions from Northern Pass, the Plan cannot come close to achieving the bold 25% reduction in GHG emissions that made headlines, even if every element of the Plan is implemented. In other words, there is a 5 million ton hole in the Plan that Massachusetts needs to fill with real and verifiable reductions.

CLF has been making this case during Massachusetts regulators’ review of the proposed merger of Northeast Utilities and NSTAR – the same companies behind Northern Pass – that week approval to form the largest electric utility in New England. Piggybacking on the Plan, Northern Pass’s developers are citing the emissions reductions from the project as the premier “climate” benefit that Massachusetts will supposedly get from the merger. That benefit appears right now to be a zero; particularly in light of the merger’s negative impacts, Massachusetts deserves a lot more to satisfy the “net benefit” standard that the merger must achieve to gain approval.

In the months ahead, we also will be pushing back against Hydro-Québec and its corporate allies in Massachusetts, who are now urging radical changes to Massachusetts’s clean energy laws that would subsidize large-scale hydropower imports, at the expense of local renewable energy projects that provide jobs and economic benefits in Massachusetts and throughout New England. The Plan itself explains the reason this is a bad idea – large hydro is a mature technology that is economic and cost-competitive without any additional public support; large hydro also has caused dramatic environmental damage and major disruptions to native communities in Canada. If imports secure little or no reduction in GHG emissions, the case for new subsidies disappears altogether.

Some may be hoping that no one is looking seriously at what Northern Pass would mean for the climate and that the Northern Pass debate will remain within New Hampshire’s borders. CLF, however, is committed to securing real scrutiny of Northern Pass’s misleading claims, ridding Massachusetts’s climate plan of its faulty reliance on Northern Pass, and advancing clean energy solutions that will, in fact, meaningfully reduce our region’s carbon footprint while enabling Massachusetts to achieve its full 25% reduction in GHG emissions by 2020.

Protesters against Keystone XL - November 6, 2011 (photo credit: flickr/tarsandsaction)

Last week, a major disaster for our climate and our nation’s clean energy future was averted – at least for now – when the Obama administration announced that it won’t consider approving the Keystone XL pipeline’s border crossing permit before it reconsiders the Keystone XL pipeline’s environmental impacts and the potential alternatives to the proposal on the table.  For all the reasons that my colleague Melissa Hoffer articulated in her post last week, the Keystone XL victory was a resounding, if limited, triumph with important lessons for environmental and climate advocates across the country as we confront, one battle at a time, the seemingly overwhelming challenge of solving the climate crisis.

The Keystone XL decision also hits home in another way. It sends an unmistakable signal that the federal government’s review process for New England’s own international energy proposal – the Northern Pass transmission project – needs the same type of new direction.

The parallels between the State Department’s Keystone XL environmental review and the mishandled first year of the U.S. Department of Energy’s review of Northern Pass are striking. In both cases, we saw:

• Troubling, improperly close relationships between the developer and the supposedly independent contractors conducting the environmental review, with unfair and inappropriate developer influence on the review’s trajectory, undermining the public legitimacy of the review process;
• An extraordinary grassroots uprising against the proposal from diverse groups of residents, landowners, communities, businesses, and conservation and environmental groups;
• Massively expensive lobbying and public relations campaigns by proponents designed to confuse and mislead lawmakers and the public
• Repeated failures by permitting agencies to ensure fair, open, and truly comprehensive review of the full range of impacts, including climate impacts, and the reasonable alternatives for meeting our energy needs in other, less environmentally damaging ways.

With all the legal, procedural, and substantive deficiencies our national advocate colleagues have been pointing out for years, the Keystone XL review (before last week) is a dramatic example of what we can’t allow to happen with Northern Pass. Right now, things don’t look good – it appears that the Department of Energy is engaging in an “applicant-driven,” narrow review of a few potential project routes, not the broad, searching analysis CLF and many others have demanded again and again (and again).  Last week’s decision to conduct a wide-ranging new review of Keystone XL shows that there is still the opportunity (and now a clear precedent) for the Department of Energy to bring the same spirit of renewed scrutiny and public responsiveness to its review of Northern Pass.

New Hampshire and New England deserve an impartial, comprehensive, and rigorous review of the Northern Pass project – and all reasonable alternatives – by the permitting agencies entrusted with protecting the public interest. Indeed, what we need now is a serious regional plan that addresses whether and how best to import more Canadian hydropower into New England and the northeastern U.S. With huge projects like Keystone XL and Northern Pass on the table, our nation’s energy future is at stake, and it has never been more important – for our communities, economy, natural environment, and climate – to get it right.

For more information about Northern Pass, sign-up for our monthly newsletter Northern Pass Wire, visit CLF’s Northern Pass Information Center (http://www.clf.org/northernpass), and take a look at our prior Northern Pass posts on CLF Scoop.

Merrimack Station in Bow, NH

In more than 50 pages of filings last Thursday, CLF responded to a pair of motions by Public Service Company of New Hampshire (PSNH) asking for dismissal of our Clean Air Act citizen suit now pending in federal district court in New Hampshire. That same day, CLF’s lawsuit got a major boost when the U.S. Environmental Protection Agency (EPA) filed a brief of its own, as a friend of the court, to identify the legal errors in PSNH’s key argument.

One PSNH motion challenged CLF’s right to sue PSNH to protect the environmental and public health from Merrimack Station’s illegal pollution. The other motion claimed that PSNH didn’t do anything wrong when it renovated Merrimack Station because EPA regulations allow it to make changes without permits.

In our briefs, CLF vigorously objects to both motions. You can download our briefs in PDF format here and here; our full set of filings, including attachments, is here (7MB .zip file).

PSNH’s illegal projects will increase Merrimack Station’s emissions, which will harm the health and well-being of CLF members. Under federal law, this harm means that CLF has the right to sue PSNH to hold it accountable for violations of the Clean Air Act. Because PSNH failed to get permits for its projects, PSNH violated the law. Those permits would require PSNH to install more stringent and protective pollution controls that all new plants must include, reducing Merrimack Station’s emissions of a wide range of pollutants, beyond the reductions that Merrimack Station’s expensive new scrubber (which is limited to reducing sulfur dioxide and mercury emissions) can achieve.

Incredibly, PSNH’s argument that it is exempt from permitting requirements is entirely based on EPA regulations that do not apply in New Hampshire. It’s not a close call; PSNH’s brief arguing for our lawsuit to be dismissed gets the rules 100% wrong, an astonishing error for a sophisticated company like PSNH, New Hampshire’s biggest utility.

EPA’s filing puts the final nail in the coffin for PSNH’s flawed legal argument. In a 25-page brief, EPA shows how, even if the rules PSNH is citing were the right ones, PSNH got those rules wrong too. As the author of the regulations PSNH cites, EPA explains that those regulations also would require PSNH to obtain permits before undertaking projects that will increase emissions.

It could not be clearer that PSNH’s recent renovation strategy at Merrimack Station — “build first, see what happens later” — violates the Clean Air Act. CLF will continue its fight to hold PSNH accountable for its violations as this case proceeds in the months to come.

Are you concerned about the Northern Pass transmission project? Do you want to learn more about what it could mean for New Hampshire and New England’s energy future, for our climate, for energy rates, and for the communities and natural environment of New England and Québec? Do you want to keep up with the latest developments as the project progresses through the permitting process?

If you answered yes to any of these questions, you’ll want to sign up for CLF’s new email newsletter – Northern Pass Wire.  In a concise format, Northern Pass Wire will provide the latest news and analysis regarding the Northern Pass project direct from CLF advocates, with links to additional resources from CLF’s Northern Pass Information Center, our latest Northern Pass posts here on CLF Scoop, and CLF’s recent legal filings. Northern Pass Wire will also keep you informed about ways you can get involved and make your voice heard as the permitting process for the Northern Pass project continues. We expect to publish Northern Pass Wire about once a month, and perhaps more frequently when events warrant. The first edition can be previewed here, and you can sign up to get Northern Pass Wire here.

Please sign up and encourage your family, friends, and colleagues to do the same!

Click on the image to preview the first edition of CLF's Northern Pass Wire

photo credit: Hope Abrams/flickr

Here in New Hampshire, the leaves have turned.  What hasn’t changed is that the environmental review of the Northern Pass proposal remains stalled while the project developers – Northeast Utilities (and its subsidiary Public Service Company of New Hampshire) and NSTAR – seek a new route for the northernmost 40 miles of the project.  It’s a disgrace that the U.S. Department of Energy (DOE) has so far refused to use the developers’ significant delay to assess the nature and extent of New England’s need for Canadian hydropower and to develop an appropriate plan to bring that power into the region, as CLF and others have been requesting since April.

While DOE is in a holding pattern, CLF is continuing to fight for a fair and comprehensive environmental review of the Northern Pass project.  Earlier this month, CLF filed new comments with DOE, supplementing the detailed comments we filed in April.  Our new comments address:

• Why CLF has renewed concerns about DOE’s control over its new environmental review contractors.  Based on our review of the Memorandum of Understanding between Northern Pass, DOE, and its new contractors, posted here (PDF), we explain that Northern Pass could still have an unfair and inappropriate influence on the content of the environmental impact statement and the schedule for completing it.
• What the Northeast Energy Link proposal means for the Northern Pass environmental review.  The recently announced Northeast Energy Link proposal, along with the Champlain Hudson Power Express project, makes it clearer than ever that we need a regional assessment of our energy needs.  These other two transmission projects also show that burying transmission lines in transportation rights-of-way is an abundantly reasonable alternative to overhead lines.
• How Northern Pass hasn’t clearly disclosed the source of power for the project.  We bring to DOE’s attention important information, obtained by CLF through its cross-examination of an executive of Northeast Utilities before Massachusetts regulators, that the source of Northern Pass’s power is likely to be new hydroelectric projects that Hydro-Québec is now in the process of designing and building.  CLF is especially troubled by the new information because the impacts of the project are much more significant if it causes the construction of new dams and the associated negative environmental impacts, including well-documented spikes in early greenhouse gas emissions from flooded land.  Northern Pass and its parent companies have consistently failed to acknowledge that these emissions undermine their claims about the reductions in emissions the project will supposedly provide.

A copy of our new comments is available here.  We also filed a Freedom of Information Act request with DOE, seeking to obtain a copy of the “Consulting Services Agreement” between Northern Pass and the environmental review contractor team.  The Memorandum of Understanding suggests that this separate contract includes important information on the budget and schedule for the environmental review, and the public deserves to know these details.

With the permitting process due to continue when Northern Pass announces a new northernmost route, CLF will be launching new ways to keep you informed about the latest Northern Pass news and the best ways for you to get involved and make your voice heard. Please stay tuned!

For more information about Northern Pass, visit CLF’s Northern Pass Information Center (http://www.clf.org/northernpass) and take a look at our prior Northern Pass posts on CLF Scoop.

photo credit: l . e . o/flickr

With each passing day, the dire reality of PSNH’s coal-fired business model is becoming clearer in New Hampshire.  The cost of operating PSNH’s obsolete power plants continues to grow, accelerating the Company’s death spiral where fewer captive ratepayers are saddled with unsustainable above-market rates as more PSNH customers choose to buy power from better managed competitive suppliers.  We are also learning that Northern Pass will make the situation worse for ratepayers, not better, and that PSNH and its Northern Pass partners are poised to pull in huge profits.  In just the last few days:

• PSNH revealed that, as it has begun bringing online its $450 million scrubber project at PSNH’s 50 year old coal-fired Merrimack Station, the bill is now coming due. If state regulators at the New Hampshire Public Utilities Commission (PUC) approve passing the cost on to ratepayers, the energy rates for PSNH customers – already the highest in New Hampshire by a wide margin – will go up by at least 1.2 cents per kilowatt hour, or almost 15%.  CLF is seeking to intervene in the PUC proceeding on the rate increase.  PSNH, unsurprisingly, wants to keep CLF out, in addition to any other party seeking to intervene on behalf of ratepayers.  There is no better illustration of the folly – for ratepayers and the environment alike – of major new investments in coal-fired power plants than PSNH’s flawed effort to extend the life of Merrimack Station.  These investments are a disaster for ratepayers, and don’t even ensure compliance with the plant’s environmental requirements – a case CLF is making right now in federal court with regard to other modifications to Merrimack Station.
• Large commercial and industrial customers with the buying power to avoid the high rates for PSNH’s fossil power continue to do so in dramatic numbers.  PSNH announced that, in September, about 82% of these customers were buying power elsewhere in the market (accounting for 93% of the power delivered to these customers) – a phemonenon known as “migration.”  Meanwhile, more than 99% of New Hampshire residents in PSNH territory were left behind to pay PSNH’s already exorbitant rates.  The scrubber rate increase is going to make this situation even worse for residents – additional businesses will find other suppliers and PSNH will need to jack up its rates even more.  More cost-effective competitive suppliers are cleaning PSNH’s clock among large customers.  Given the company’s excessive and increasing rates, residential ratepayers are starting to vote with their pocketbooks for more sustainable energy supplies.
• It is becoming increasingly clear that the current Northern Pass proposal is designed around PSNH’s bottom line, not the interests of New Hampshire ratepayers.  As we’ve mentioned before, the large customer “migration” problem and its upward pressure on homeowners’ electric bills are likely to get worse with Northern Pass, which would further depress regional wholesale electric rates and encourage more customers to leave PSNH.   Adding in the cost of the scrubber will only widen the divide between the businesses that can choose other suppliers and potentially benefit from Northern Pass, and the residential customers who are currently  stuck with PSNH. A new wrinkle emerged last week – testimony from PUC staff showing that PSNH’s consultants estimated a year ago that Northern Pass will cannibalize PSNH’s already meager revenues from Newington Station, PSNH’s little-used power plant in Newington, New Hampshire, that can operate with either oil or natural gas.  Northern Pass would mean it would almost never run and that the investments ratepayers have made over the years to keep Newington Station operating will essentially be lost.  This same dynamic will apply to the rest of PSNH’s power plants:  Northern Pass will diminish their market value further exposing New Hampshire businesses and residents to the risk of excessive costs.  Once again, a series of poor decisions and self-interested advocacy by PSNH (at the expense of ratepayers) is forcing the legislature to intervene.

The costs of PSNH’s coal-fired power plants are becoming untenable, and a radically redesigned Northern Pass proposal and other alternatives could help PSNH meet its customers’ power needs more cheaply and with less damage to public health and the environment.  Instead of planning for a cleaner energy future, PSNH is working only to preserve its regulator-approved profits.  CLF will be using every tool at our disposal to force a rethinking of PSNH’s approach.

The Eastmain Powerhouses from space (photo credit: NASA)

Beyond the discredited sales pitch that Northern Pass will lower electric rates in New Hampshire, the developers have repeatedly claimed that the power to be imported through the Northern Pass project will be “low-carbon,” “clean,” and “green,” with “no greenhouse gases,” and “no global warming.” The power will also, we’re told, “improve the quality of the air we breathe.” The developers have said, over and over, that the project “is expected to reduce regional carbon dioxide emissions by up to 5 million tons per year, the equivalent of removing from the road one million cars annually.” In fact, the study on which this claim is based – a report (PDF) commissioned by Northern Pass and authored by Boston-based energy consultant Charles River Associates – began with the assumption that hydro power is “zero-carbon.” Let me repeat that: the developers’ claim that the project will reduce carbon dioxide emissions by a net 5 million tons is based on their unexamined presupposition that the power to be delivered by the project has no carbon dioxide emissions at all.

There’s no other way to say it: this assumption is false.

You don’t have to take my word for it; read Hydro-Québec’s own research report (4.4 MB PDF) on the net greenhouse gas emissions of the Eastmain 1 Reservoir, flooded in 2005 (aerial shots here). In an Orwellian twist, the developers of Northern Pass have repeatedly cited this very same research.

The Hydro-Québec report found that net carbon emissions from Eastmain-1 were 500,000 tons in 2006 and 165,000 tons in 2009, and are projected to average approximately 158,000 tons per year on a long-term basis.  While certainly less than coal-fired power plants – PSNH’s Merrimack Station emitted more than 2.8 million tons of carbon dioxide in 2010 – 158,000 tons of net carbon emissions per year is far from ”zero-carbon” or even “low-carbon” power.  Based on our own survey of reservoir greenhouse gas research, we have some serious questions about the report, and there is reason to believe that it understates emissions over time and per unit of energy generated. But the report does confirm that Hydro-Québec’s reservoirs will continue to emit more greenhouse gases per year than the natural environment they flooded. These emissions are locked in for decades if not centuries – unlike a power plant that burns fuel, you cannot turn off a reservoir.

When compared with the power plants that Northern Pass’s power could displace, new hydroelectric projects in their early years of operation are no cleaner in terms of carbon emissions.  According to the report, ”it takes about five years for the accumulated CO2 eq. emissions to fall below the [natural gas combined cycle] value” (p.15). So, on a net and cumulative basis since its flooding in 2005, the Eastmain 1 Reservoir has had the same carbon dioxide-equivalent emissions as a modern natural gas power plant that has the same power output and began operating in 2005. 

The report also highlights what appears to be a clear difference between the net emissions of a newly impounded reservoir and the emissions of a reservoir that was impounded decades ago: a new reservoir emits more greenhouse gases, as the vegetation and organic material in the newly inundated area decompose.

This distinction is especially important when considering the contradictory stories we have heard about where Northern Pass will get its power. On the one hand, Northern Pass’s website claims (click on “Hydro-Québec” on this page) that “Hydro-Québec does not need to build any new generation to support this project.” On the other hand, it is clear that Québec is developing and planning vast new hydroelectric projects, many of which will require new inundation and reservoirs, as part of a concerted strategy to maintain and increase exports to New England and the northeast United States. See Erin’s blog post from yesterday for more on Vermont’s new long-term contract with Hydro-Québec. 

In fact, Charles River Associates’ fundamentally flawed estimate of carbon emissions reductions depends on the development of new hydro projects in Canada. And just ten days ago, in testimony to Massachusetts regulators, Northeast Utilities’ CFO David McHale stated under oath: “We already know for a fact that the utility Hydro-Quebec has initiated the construction of dams, and we’ve already entered into the record a discussion about the Eastmain Water Reservoir that will provide the water source. So this is not speculative. They’re building the dams and they will go into service; and that will be the primary source, if not the exclusive source, of energy that will flow over [the Northern Pass] line. . . . [T]hat is the full expectation.” What McHale was referring to is Hydro-Québec’s major new project in the vicinity of Eastmain-1 – the Rupert River project (project website here and explanatory animation here). Since 2009, this 918-MW project – now in the final stages of development – has newly flooded 346 square kilometers  - an area about the size of two Lake Winnipesaukees. That Northern Pass power will be coming from new projects means that Northern Pass will enable and contribute to the substantial carbon emissions associated with new reservoirs.  There has been no accounting of the potential emissions from the Rupert project and other future projects that Northern Pass may make possible, and how they would cut into the potential emissions reductions Northern Pass and Charles River Associates have claimed.

These inaccuracies and contradictions are being disseminated with hundreds of thousands of dollars in media buys, money which could have been invested in engaging in a collaborative process to rework the current proposal.  This situation makes CLF’s fight for a world-class, independent, and comprehensive permitting process all the more important.

CLF has been adamant that the Department of Energy must consider the environmental impacts – including greenhouse gas emissions – of the hydropower generation projects and any other power plants in Canada that will supply the Northern Pass project.  Given the developers’ recent announcement of new delays in their schedule, there’s still time for the Department of Energy to change course and answer our call for a regional, holistic analysis of the right approach to importing power from Canada, taking into account the truth about that power’s greenhouse gas emissions.