On the cusp of the Northern Pass transmission project’s fourth year, it is no closer to community acceptance, government approvals, or construction. But, for the first time since 2011, the permitting process is moving forward once again, as are the developer’s efforts to sell the project to a skeptical Granite State. That means new opportunities to register your concerns with the federal agency reviewing the project and to provide feedback directly to the people on the developer’s team. Here is a Northern Pass update.
The project came back from a long lull this summer, with the developer, Northern Pass Transmission LLC (NPT), announcing a slightly revised “new” route, initiating a new statewide marketing campaign (complete with long-discredited talking points), holding “open houses” for some towns that would be affected by the project, and unveiling a plan to create a fund to support North Country jobs if the project is approved. Meanwhile, op-ed and letter writers took to the state’s and region’s newspapers to renew the public debate about the project.* A key obstacle to Northern Pass’s revised proposal immediately emerged: it is unclear that the project has the legal ability to use several miles of North Country roads.
In July, the developer filed an amended application for a Presidential Permit to U.S. Department of Energy (DOE). Earlier this month, DOE published a notice in the Federal Register that it had received the amended application and that it would accept public comments on the filing.
The federal permitting process for Northern Pass will include a full environmental review of the entire project, evaluation of alternatives to the current proposal, and special consideration of the proposed sections that cross the White Mountain National Forest. It is now clear that the federal government’s review of the project will be a critical part of the state’s consideration of the project’s application for state approval as well. As CLF has said from the beginning, by law and as a matter of good government, New Hampshire deserves a federal permitting process for Northern Pass that is comprehensive, rigorous, open, and fair.
While the defects in DOE’s passive and troubling approach thus far have not been addressed, what is encouraging is that, earlier this month, New Hampshire’s Congressional delegation, in an extraordinary moment of bicameral, bipartisan unity, requested improvements in DOE’s handling of the permitting process to ensure a “thorough, transparent, and effective” environmental review, including the public release of information about the project’s impacts and the alternatives to be studied. Their full letter to DOE Secretary Moniz is here. (In a separate letter, the delegation also jointly asked the Secretary of Agriculture to reaffirm that the terms of the Connecticut Lakes Headwaters Easement would not allow the Northern Pass project to use the conservation land it protects, the only project alternative that NPT included in its amended application.)
If you are concerned about Northern Pass, you have three immediate opportunities to weigh in on the project and its amended permit application:
- Submit comments to DOE on Northern Pass’s amended application.
The application is a lengthy document with additional information on the project and a number of exhibits, but much of the proposal is exactly the same as the proposal that has been on the table for almost three years. This is an opportunity to tell DOE, for example: what your concerns are with the project, what you think of the changes to NPT’s proposal, what you think is missing from the application, whether NPT’s discussion of alternatives is adequate, and whether DOE should require NPT to submit more information for public review before the permitting process continues. You may file comments by sending them to Christopher.Lawrence@hq.doe.gov and then sending a hard copy of the comments to Christopher Lawrence, Office of Electricity Delivery and Energy Reliability (OE-20), U.S. Department of Energy, 1000 Independence Avenue SW., Washington, DC 20585. The deadline for submitting comments is September 18.
Regardless of this deadline, you can continue to file “scoping comments” on DOE’s environmental review of Northern Pass at http://www.northernpasseis.us/. DOE has not announced a deadline for those comments.
- Request intervener status in the DOE permitting process.
You should consider filing for intervener status if you want to play an ongoing role in the process. Landowners, residents of affected communities, and interested organizations, as well as local communities and municipal boards should consider filing for this status, if they didn’t do so in 2010 (a list of those that did is here). To give you an idea of what an intervention filing looks like, take a look at CLF’s filing from 2010 (20 MB PDF). Another simpler example is the 2010 filing of the North Country Council. The requirements are spelled out in federal regulations (18 C.F.R. 385.214) and DOE’s Federal Register notice. The deadline for filing for intervener status is September 18.
- Attend a developer-sponsored open house.
This is your chance to speak your mind and ask hard questions. Let us know what you hear! The next open house is in Concord on September 4, and more are scheduled. Here are some suggestions:
- These open houses seem to be targeted at residents and landowners; project representatives have maps and computer programs to show where the project would be located. Find out how the project would affect your town or places that are special to you, and tell the representatives what you think about the impacts.
- Ask project representatives to explain if and by how much the project will reduce your energy bill, especially if you are a PSNH customer.
- Ask why they continue to use an estimate of the project’s climate benefits that is completely untrue.
- Ask why the project is not proposing to use the new imports to phase out PSNH’s dirty, costly coal plants.
- Ask why siting a non-reliability transmission project in roadbeds owned by unwilling landowners is different from using eminent domain.
- Ask why underground transmission technology is not an option for more of the project.
- Ask why the proposed jobs fund contributions are less than 1% of the project’s annual profits.
- Insist that project representatives follow up and provide information and proof in response to your questions in writing.
- Keep in mind that these open houses are not part of the public review process for the project. They are a public relations gesture and a showcase for NPT to get its message out. Whether or not they reflect any form of honest engagement with the public remains to be seen.
There will be many future opportunities to participate in the federal and state permitting processes for Northern Pass, including at additional scoping meetings for the federal environmental review, which have not yet been scheduled but will likely be later this fall. We’ll keep you posted. UPDATE: DOE has announced the final round of public scoping meetings for the project’s environmental review for the week of September 23. More on those meetings here.
* A sampling of the many thought-provoking pieces authored by concerned citizens this summer:
- Lee Sullivan, Northern Pass Project Power Is Not Needed (Foster’s Daily Democrat)
- Nancy Martland, Unneeded Power Line Would Scar New Hampshire (Hartford Courant)
- Dolly McPhaul, How Dare They? PSNH Exploiting NH (Nashua Telegraph)
- Kathy Sullivan, Northern Pass Numbers Do Not Add Up (Manchester Union Leader)
- Fergus Cullen, Northern Bailout – PSNH, Public Assets and Private Profits (Manchester Union Leader)
- Terry Cronin, Psst, PSNH, Why Not Join the 21st Century? (Concord Monitor)