Leaves are falling, autumn has arrived – and so has a new look for CLF Ventures, CLF’s non-profit strategy-consulting arm. CLF Ventures bridges the public and private sectors to advance innovative, market-based solutions that benefit the environment, society, and our clients’ bottom line. With a new logo and a newly redesigned website, CLF Ventures is taking our message of “Environmental Gain – Economic Advantage” to the next level.

The new CLF Ventures logo was designed to complement the CLF logo while capturing the unique mission and value that CLF Ventures brings to our clients. The two overlapping leaves in the new CLF Ventures logo embody our message that the environment and the economy are interconnected, not mutually exclusive, and that we need to pay attention to both to have a truly thriving and sustainable economy. “If you really look closely,” says CLF Ventures CEO Jo Anne Shatkin, “you see the “V” inside the leaves – that’s the “V” for Ventures, but it’s also a check mark, which says ‘yes, we know how to make things happen.’ CLF Ventures is like those two overlapping leaves. We’re uniquely positioned to help our clients because we’re part of the environmental community and we understand what businesses and innovators need to operate and thrive.”

The redesigned CLF Ventures website highlights the breadth of our services and the wide variety of partners we help. Our new homepage features a revolving showcase of the “Four I’s” – Innovate, Incubate, Integrate, and Initiate – which captures CLF Ventures’ mission to bring about positive environmental change through the marketplace. Many people are familiar with CLF Ventures’ work to help facilities integrate their operations with sound environmental principles and operate both sustainably and profitably. But CLF Ventures also helps entrepreneurs and clean technology leaders innovate their products and technologies and bring them to market. We incubate replicable, new businesses that create shared value and improve the environment. And we initiate opportunities that propel new investment models toward the triple bottom line. Our redesigned website allows us to share our story – and our mission – with a broader audience. We hope you’ll check out www.clfventures.org and let us know what you think.

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.

Merrimack Station Coal Plant. Photo credit: flickr/Jim Richmond

New England’s old coal-burning power plants don’t just pollute the air. With their obsolete cooling technology, they also create havoc in the water bodies on which they reside. To control heat from the coal-combustion process, these coal plants draw millions of gallons of water daily into their antiquated cooling systems, killing the aquatic life that gets sucked in with it, and then discharge the super-heated, chemical-laden  water back into the fragile rivers and bays, where it creates untenable living conditions that destroy native fish and other species.

Under decades of pressure from CLF and other organizations, EPA has tightened its regulations around water intake and discharge at the region’s coal plants. At the GenOn Kendall Power Plant in Cambridge, MA, as a result of a lawsuit brought by CLF and the Charles River Watershed Association, EPA required last February that the plant owner, TriGen Corporation, build a “closed-cycle” cooling system that will reduce the water withdrawal and discharge of heated water into the Charles River by approximately 95%. Brayton Point in  Fall River, MA will finish construction of its new cooling towers in 2012, dramatically reducing its harmful impacts on Great Hope Bay.

Today, in another giant step forward, EPA issued a draft NPDES permit for Merrimack Station in Bow, NH, where heated discharge from the power plant’s old “once-through” cooling system has caused a 94 percent decline of the kinds of species that once lived in that part of the Merrimack River. CLF applauded the draft permit, which will require Public Service Company of New Hampshire (PSNH) to install and operate year-round a modern cooling system that will decrease the plant’s discharge of heated water by nearly 100 percent.

In a statement, issued today in response to the release of the draft permit, CLF called the requirements “long overdue.” Jonathan Peress, director of CLF’s Clean Energy and Climate Change program, said, “No matter what PSNH spends, it will not be able to turn this 50-year-old dinosaur into an economically-viable generating facility that benefits the people of New England. Still, as long as this plant remains in operation, it must comply with the law and we commend EPA for holding PSNH accountable.” Read the full statement here.

CLF President John Kassel (right) accepts check for a Clean Diesel project from EPA Region 1 Administrator Curt Spalding

CLF Ventures, Conservation Law Foundation’s non-profit consulting affiliate, has been awarded an EPA grant to help two New England charter fishing vessels reduce their diesel emissions. The project will repower four “tier 0″ marine engines on the vessels The Atlantic Queen, out of Rye, NH and The Captain’s Lady II, out of Newburyport, MA. Jo Anne Shatkin, PhD, CEO of CLF Ventures, said the funding will allow CLF to work with the two vessels to reduce their impacts on air pollution and greenhouse gas emissions and to reduce fuel costs.

EPA’s Clean Diesel projects help create and retain jobs, as well as reduce premature deaths, asthma attacks and other respiratory ailments, lost work days and other health impacts associated with air pollution from diesel engines. John Kassel, CLF president, accepted a check for $391,500 from EPA Region 1 Administrator Curt Spalding at a ceremony today in Boston. Read EPA’s press release here.

A new report released today indicates that a proposed Clean Fuels Standard could significantly strengthen the economy and boost energy self-sufficiency in the Northeast and mid-Atlantic by saving Americans billions in personal disposable income, bringing in billions more for participating states, and creating up to 50,000 jobs per year.

The analysis, conducted by the Northeast States for Coordinated Air Use Management (NESCAUM) on behalf of 11 northeast and mid-Atlantic states, shows that creating a Clean Fuels Standard would help strengthen the region’s economy while reducing America’s reliance on oil and our exposure to volatile oil prices by supporting a clean energy economy here at home.

It enumerates multiple economic and environmental benefits the standard could deliver in the next 10 years, including:

• Creating up to 50,000 jobs annually
• Increasing personal disposable income in the region by up to $3.2 billion
• Growing our state economies by up to nearly $30 billion dollars
• Reducing our region’s dependence on oil by as much as 29 percent
• Reducing harmful air pollution that causes climate change up to 9 percent

Under a Clean Fuels Standard being considered, oil companies would make their fuels 10 percent cleaner on average when it comes to carbon pollution, allowing them to do this any way they choose (such as boosting sales of electricity for electric vehicles, advanced biofuels or natural gas). This means billions of dollars would be reinvested in the states to develop clean, local alternatives to gasoline and diesel – rather than sending them overseas.

CLF is encouraged by the report’s positive findings. Sue Reid, director of CLF Massachusetts, said, “The status quo of continuing to burn billions of gallons of gasoline and diesel fuels year after year is unsustainable on every level. With gas prices a dollar higher than this time last year, our region should seize on this good news that cleaner alternatives present real economic opportunity for the region. A Clean Fuels Standard provides a viable path to meeting our greenhouse gas reduction targets, and a way off of the fossil fuel roller coaster.”

Read reaction from other leading environmental and science organizations who support the Clean Fuels Standard here.

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.

PSNH: In a death spiral? (photo credit: CC/Nick Seibert)

In every possible way – on television, in mailings, and on the web – New Hampshire has heard again and again that the proposed Northern Pass transmission project will reduce electric rates for New Hampshire customers. The claim is at the core of PSNH’s case that the project is a good deal for New Hampshire. If only it were true…

As I mentioned in a post last month, the very design of the project as it stands is for reduced electric rates to benefit only those ratepayers that get their power from the regional electric markets. In New Hampshire, homes and small businesses in PSNH territory would see very little benefit because their energy rates are overwhelmingly tied to propping up PSNH’s old, inefficient fleet of coal-fired and oil-fired power plants.  These plants would not be able to compete with other cleaner power sources if forced to compete in the marketplace, something New Hampshire law does not currently allow and PSNH has fought to avoid. (Supposedly, an agreement between PSNH and Hydro-Québec for some power for PSNH customers is in the works, but, if it ever materializes, Northern Pass has said it would only be for a small amount of power, which would not do much to change PSNH’s overall portfolio. Northeast Utilities admitted as much in testimony before the Massachusetts DPU this week and also noted that there is “really little activity” around securing any such agreement.)

As explained in a piece on NHPR featuring our own Jonathan Peress, the above-market costs of PSNH’s aging fleet are causing large customers to buy power from (or “migrate” to) cheaper suppliers. Regulators this week turned back PSNH’s attempt to saddle those customers with its fleet’s escalating costs. But this situation is creating a so-called “death spiral,” because PSNH is forced to raise its rates again and again on a shrinking group of customers – homeowners and small businesses who do not have the purchasing power to contract with another supplier.

What does this all have to do with Northern Pass? The truth is that Northern Pass will – indeed, is intended to – make the “death spiral” worse.  If Northern Pass lowers the regional price of power as all those ads proclaim, it will make PSNH power even less competitive, causing even more customers with choices to leave PSNH behind.  PSNH spokesman Martin Murray so much as promises that result when he says in the NHPR piece that Northern Pass power will not displace PSNH generation. As Jonathan explained on NHPR, that means that the same homeowners and small businesses that will have to deal with 180 miles of new transmission lines will have higher, not lower, electric rates. This is not the Northern Pass story PSNH has been telling.

None of this makes sense. PSNH’s coal- and oil-fired power plants are bad for ratepayers and disasters for public health and the environment. As our lawsuit filed last week makes clear, PSNH’s efforts to prop up its largest plant failed to comply with even basic emissions permitting requirements and have increased that plant’s emissions. Any plan to import Canadian power with PSNH’s name on it should provide real benefits to its own customers and focus on responsibly freeing New Hampshire (and the lungs of millions of New Englanders) from PSNH’s dirty, uncompetitive dinosaurs.

ADDED: I should also point out, in the same Massachusetts DPU proceeding mentioned above, that counsel for NSTAR (the junior partner in Northern Pass) asserted that “[i]t’s entirely speculative as to what the impact of Northern Pass will be on rates in New Hampshire, and then [migration].”  Quite a statement given Northern Pass’s public relations campaign asserting that rates will go down. And we disagree with NSTAR’s counsel wholeheartedly. It is reasonable – not speculative – to expect the current proposal will lead to higher rates for PSNH ratepayers.

Merrimack Station power plant in Bow, NH. (Photo credit: John Moses)

Today CLF filed a federal Clean Air Act citizen suit in New Hampshire federal district court against Public Service Company of New Hampshire (PSNH), the owner of Merrimack Station power plant for the plant’s repeated failures to obtain required air permits. CLF’s citizen suit also cites numerous violations of Merrimack Station’s current permits and the resulting illegal emissions from the plant.

Merrimack Station  is among the most polluting coal-fired power plants in New England and is the single largest source of greenhouse gas emissions in New Hampshire, releasing over 2 million pounds of toxic chemicals every year. In addition, the plant is causing PSNH’s energy rates (already the highest in New Hampshire) to steadily climb as ratepayers are forced to foot the bill for the above-market cost of keeping PSNH’s old coal plants in operation.

CLF’s complaint contends that the plant, which is more than a half-century old and is in the midst of a major, multi-faceted life extension project, never obtained required permits authorizing renovations to major components of Merrimack Station, including much of an electric-generating turbine, even though the changes increased pollution from the plant.  As predicted by PSNH’s own projections, the changes led to more emissions of pollutants, including smog-causing nitrogen oxide and particulate matter, or soot, which causes respiratory problems when inhaled and is linked to increased hospitalizations, lung damage in infants and children, and premature death.

“In the course of this project, PSNH has repeatedly violated the Clean Air Act, putting the health of the public, especially children and senior citizens, at risk,” said Christophe Courchesne, CLF staff attorney. “PSNH is not above the law and CLF is committed to holding them accountable. With PSNH trumpeting the supposed ‘clean air’ benefits of the Northern Pass project with full-page ads in newspapers across New Hampshire, it is imperative to shine a light on PSNH’s coal plants, which easily cancel out the purported benefits of Northern Pass.” Read more >