CLF and Allies to Department of Energy: Take off the Blinders in Northern Pass Review

Jul 3, 2014 by  | Bio |  6 Comment »


(photo credit: Proimos)

Back in May, the U.S. Department of Energy (DOE) issued a report listing the alternatives to the Northern Pass transmission project that the agency may study during its environmental review. As I explained at the time, the report was a hard-won victory for transparency in the federal permitting process for Northern Pass. Unfortunately, the report failed to answer key questions, to include obvious and reasonable alternatives, or to demonstrate that the agency was independently and impartially considering the public’s feedback.

Last week, CLF and several environmental allies explained the problems with the alternatives report in detailed comments to DOE and the other federal and state agencies participating in the environmental review (PDF here, 6MB .zip archive of exhibits here). Our message: DOE must consider a broader set of alternatives to the project than those listed in the report and take additional steps to ensure a fair, open, and thorough process. We make these specific points:

  • Despite enumerating underground alternatives that would make use of Interstate 93, DOE inexplicably ignored alternative configurations that would make use of the Interstate 91 corridor and the Derby Line border crossing. Likewise, DOE failed to list many project routes that would be possible if the project’s Deerfield, New Hampshire terminal station were relocated to another substation elsewhere in central or southern New England.
  • DOE fails to list the obvious alternative of making full use of existing transmission lines that originate in Québec. As CLF highlighted last year, those lines are rarely full to capacity, and modest transmission equipment upgrades in neighboring New York could allow for much greater power flows.
  • DOE improperly continues to list an alternative route, included in Northern Pass’s developer’s amended permit application, that would illegally cross the Connecticut Lakes Headwaters Easement in northern New Hampshire, in violation of federal and state land conservation commitments.
  • There are troubling indications in the alternatives report that Northern Pass’s developer continues to have a major influence on the direction and scope of DOE’s environmental review through private communications with DOE that have not been disclosed. This needs to stop, and we propose a number of steps that DOE should take to make the process more transparent, such as announcing the alternatives DOE intends to study in detail prior to release of its draft environmental impact statement, adding to its website all information provided to the agency or its consultants by Northern Pass’s developer, and convening a stakeholder committee with public meetings to receive regular updates on the process and advise DOE on its work.

But our most important request is one that several of our groups have made before: DOE should take a regional view and evaluate all pending north-south transmission proposals together in one comprehensive environmental and economic study. While our motion for such a study in 2011 highlighted the still pending Champlain Hudson Power Express project in New York and Hydro-Québec’s ambitious export plans, a flood of new transmission proposals to import Canadian hydropower have emerged since then. Most recently, Northern Pass’s own sponsors—Hydro-Québec and Northeast Utilities—have themselves submitted interconnection requests for additional international transmission projects between Québec and Vermont. While DOE’s alternatives report does briefly mention several earlier projects as potential Northern Pass alternatives, its list is incomplete, and it’s not clear from the report that DOE intends to study them in detail.

Under federal law, DOE is charged with taking a “hard look” at the environmental and economic impacts of these projects and determining whether they are “consistent with the public interest.” If DOE is to meet its obligations, conducting silo-ed permitting processes for each project without taking a broader view first makes very little sense. As the New England governors are pursuing a rushed regional deal to fund new transmission projects with apparent disregard for comprehensive and rigorous environmental and economic analysis, it is essential that DOE and the other agencies involved carefully review Northern Pass in the context of all the other proposals vying to bring Canadian hydropower south and their alternatives, including local renewables and energy efficiency.

It is not too late for the federal environmental review of Northern Pass to take off its blinders and change course. Please join CLF and our allies—the Appalachian Mountain Club, the Nature Conservancy, and the Society for the Protection of New Hampshire Forests—in calling on DOE to consider a broader range of alternatives to Northern Pass in a comprehensive environmental impact statement on the full list of transmission projects that New England is considering. You can submit a comment on DOE’s website here.

Learn more about Northern Pass here or by signing up for CLF’s email newsletter, Northern Pass Wire. For the latest Northern Pass updates,  follow me on Twitter.

Small Step on a Long Hike: DOE Plans to Consider a Long List of Northern Pass Alternatives

May 2, 2014 by  | Bio |  1 Comment »

Yesterday, the U.S. Department of Energy (DOE) published an update on the Northern Pass project permitting process, offering the first signals of which alternatives to the developer’s proposal DOE will evaluate during its environmental review process.

Posted to DOE’s website, the report is compellingly titled a “scoping report alternatives addendum” and provides a list of the 24 alternatives DOE has identified to date “for analysis” in its draft Environmental Impact Statement, or “EIS.” DOE compiled the list from information provided by the developer, DOE’s own work, the many public scoping comments on alternatives, and input from other government agencies. They range from the “no action” or no-build alternative to underground transmission lines to non-transmission alternatives like further energy generation and conservation within New England. (The report is an addendum to DOE’s unremarkable report, published in March, that briefly summarizes the EIS scoping process that ended last November as well as the thousands of public comments on the project.)

The report is an important but modest step towards transparency in an embattled three-year permitting process that has been all too susceptible to the perception that it is proceeding myopically and under the inappropriate and excessive influence of the project developer, Massachusetts- and Connecticut-based Northeast Utilities. It took a three year effort by CLF and our advocacy partners, as well as the extraordinary, sustained commitment of the entire New Hampshire Congressional delegation, speaking with one voice on three occasions, to win DOE’s agreement to publish the report.


A DOE-identified underground alternative to Northern Pass along state roads through the White Mountain National Forest

As much as the fact of the new alternatives report is a step forward, the report itself is something of a disappointment. Although there are a few silver linings, the report fails to answer a number of key questions about the direction of DOE’s review of Northern Pass.

Our observations:

  • DOE stops short of defining which alternatives on the list are “reasonable alternatives” that will be studied in detail in the EIS. This is the key information that the public should know before DOE commits its resources to preparing a massive report on those alternatives. Indeed, defining what alternatives are “reasonable” is the decision that will determine whether DOE is undertaking a truly comprehensive analysis or is following the overly narrow approach that Northeast Utilities would prefer. All we have now is a list, with no indication of how the list will be narrowed down as DOE prepares the EIS. An aside: if DOE has not yet made these decisions, it clearly has a very long way to go before it publishes a complete draft EIS, and it is hard to see how DOE will meet its end-of-2014 target for releasing the document.
  • DOE lacks a set of clear, guiding principles for selecting which alternatives should be studied. To identify alternatives to a project, it is important to know the “purpose and need” for the project that alternatives should fulfill. In this case, DOE continues to say, in circular fashion, that the “purpose and need” for its review of Northern Pass is to consider whether to grant a permit to Northern Pass. As CLF and our advocacy partners have pointed out on numerous occasions, this is an illegally narrow definition that does not provide a helpful framework for identifying an appropriately broad set of alternatives.
  • DOE is too focused on identifying routes and configurations for transmission lines beginning in Pittsburg, New Hampshire, and ending in Deerfield, New Hampshire, reflecting Northeast Utilities’ preference. There are numerous other potential border crossings and terminal stations for a new transmission line (including New Hampshire substations and power plants owned by Northeast Utilities’ subsidiary PSNH but also in other states). Although the report describes a number of important alternatives that do not involve power lines between these two points, the report’s descriptions of many of those alternatives are much more cursory and vague, raising the concern that the DOE will not study them with adequate detail or seriousness.
  • The most encouraging aspect of the report is that DOE seems to have made a serious effort to identify and map underground alternatives to Northern Pass. About half of the alternatives listed include some underground component, and several involve complete burial of transmission lines. The report defines potential underground routes and describes key technical imperatives—such as a relocated converter station—for an underground project. As I’ve argued, underground alternatives are cost-competitive with overhead transmission lines and must be rigorously evaluated in the EIS. To the extent the report signals that several underground transmission configurations and routes will be studied in detail in the EIS (over Northern Pass’s strenuous objection), it’s good news and exactly what the New Hampshire environmental community and many others in New Hampshire have been seeking.
  • Northeast Utilities’ praise of the report rings hollow. In a statement on its project blog and on this morning’s quarterly investor call, Northeast Utilities welcomed the report. It’s an odd stance given that Northeast Utilities opposed the environmental community’s request for the report until days before DOE agreed to prepare it, and its amended permit application filed last year reads more like a legal brief against robust consideration of any alternatives (save one potential—and illegal—route through the Connecticut Lakes Headwaters conservation easement area in far northern New Hampshire). Moreover, trumpeting a report that highlights the many strong alternatives to the current proposal as some kind of evidence that the process is moving toward near-term approval of the project marks an unfortunate continuation of the project’s utterly disingenuous (and apparently ineffective) public relations campaign.

As CLF has argued for three years, DOE’s choice of which alternatives to study is crucial. Elected officials and the public have repeatedly voiced strong interest in alternatives to the current proposal, and a comprehensive and rigorous alternatives analysis is fundamental to reaching well-informed decisions on the project’s permit applications. Indeed, an objective and thorough analysis of alternatives is commonly considered “the heart” of the National Environmental Policy Act—the law DOE is required to implement as part of its permitting process. Despite encouraging signs in DOE’s alternatives report, it remains to be seen whether DOE will do the detailed study of Northern Pass alternatives that federal law requires and New Hampshire deserves.

Learn more about Northern Pass here or by signing up for CLF’s email newsletter, Northern Pass Wire. For the latest Northern Pass updates,  follow me on Twitter.

Finally: A Win for Transparency in the Federal Review of Alternatives to Northern Pass

Feb 11, 2014 by  | Bio |  Leave a Comment

CLF is celebrating a recent decision that will shine some sunlight into the permitting process for the Northern Pass project. Last week, the New Hampshire Congressional delegation announced that the U.S. Department of Energy (DOE) will in the near future publish a preliminary report on which alternatives to the Northern Pass project will be studied in DOE’s draft Environmental Impact Statement (EIS). The draft EIS is not expected until late 2014 at the earliest. The delegation had come together, first in August of last year and again in January, to request this report.


A forthcoming report from the Department of Energy will reveal which alternatives to Northern Pass will be studied during its environmental review. (photo credit: flickr/ecstaticist)

This news marks the successful conclusion of a three-year effort initiated by CLF and several partnering organizations. The rationale for the report is simple. As we said in our original March 31, 2011 letter that first requested the report, the preparation of the EIS is a massive and complex undertaking; at its core, the EIS must include a comprehensive analysis of reasonable alternatives to the applicant’s proposal. It is essential to the overall permitting process that DOE make well-informed and appropriate decisions regarding which alternatives are reasonable and will be studied in detail in the EIS. If DOE is missing key alternatives, the report will allow the public to have an opportunity to make the case that more alternatives should be studied, in time for DOE to change course and study those alternatives in the draft EIS. The public and New Hampshire policymakers have a clear and growing interest in alternatives to the current proposal: witness the New Hampshire House’s recent passage of a bill that would require careful analysis of underground alternatives to overhead, elective transmission projects like Northern Pass within the state siting process. CLF has been fighting for this report for three years and repeatedly renewed our 2011 request, including at last September’s scoping meetings.

This win for transparency is the second time that New Hampshire’s U.S. Senators have succeeded in a joint effort to ensure a fair permitting process: three years ago, they raised concerns, first identified by CLF and several other organizations, that the initial contractor for the EIS had a significant conflict of interest because it was simultaneously working for DOE and for project developer Northern Pass Transmission LLC (NPT) as its consultant in the New Hampshire state permitting process. Under pressure, NPT withdrew the contractor from its role with DOE, and DOE replaced the contractor with a new EIS contractor team. While CLF and many others remain concerned with the flawed process DOE used to select the new team, the EIS is at least no longer in the hands of a contractor that also is being paid to advocate for NPT. The delegation’s latest effort is another sign that there is strong and persistent bipartisan commitment among New Hampshire leaders to ensuring that DOE’s review of Northern Pass is objective, comprehensive, and well-informed.

A final observation on this alternatives report: both DOE (p. 7 of this pdf) and NPT (p. 12 of this pdf) originally opposed issuing it. NPT abruptly changed its position shortly after the delegation’s second letter in January, and DOE followed suit. CLF is grateful that the delegation stood together once again to push DOE toward common-sense steps that will help ensure a better permitting process for Northern Pass.

Read more about alternatives to Northern Pass in our ongoing series hereLearn more about Northern Pass here or by signing up for CLF’s email newsletter, Northern Pass Wire. For the latest Northern Pass updates, follow me on Twitter.

NH Delegation: Public Deserves More Information on Northern Pass Alternatives

Jan 19, 2014 by  | Bio |  Leave a Comment

The long effort to assure a fair, rigorous permitting process for the Northern Pass project got a boost last week, as the New Hampshire Congressional delegation came together to demand, yet again, transparency regarding how that process will address alternatives to the current proposal.

Over the next year or so, the U.S. Department of Energy (DOE) will prepare an extensive study of the Northern Pass project, its many impacts on the environment, and the reasonable alternatives to the developer’s proposal, known as the Environmental Impact Statement or EIS. That document must comply with the requirements of a landmark federal law, the National Environmental Policy Act of 1969, and will help determine whether DOE grants the project a Presidential Permit and whether the U.S. Forest Service grants the project a permit to cross the White Mountains. It will also have a major influence in the state siting process. In light of the document’s importance, CLF and many thousands of other stakeholders participated in the official “scoping” process for the EIS, which concluded in early November.


What’s the plan for the Northern Pass EIS? (photo credit: flickr/danxoneil)

DOE says that its next step is to release a “scoping report” that describes the process, the public scoping meetings held in 2011 and 2013, and the thousands of written comments received from the public. Many months after the scoping report is released, DOE will publish a draft EIS, likely with thousands of pages of text and appendices, which will analyze the project and the alternatives DOE deems “reasonable” in great detail. The public will then have a limited time to comment on the draft EIS.

Unfortunately, this process is now leaving the public in the dark regarding a critical issue: which alternatives—such as burial of the transmission line, and alternative routes—DOE intends to study in detail in its EIS.

In a joint letter this week, the New Hampshire Congressional delegation asked DOE to take an essential interim step—to release a report identifying the alternatives DOE plans to study in detail in the EIS:

As we have previously emphasized, it is of the utmost importance that New Hampshire citizens are provided an opportunity to have input on a thorough, transparent, and effective EIS study. Given the public’s immense interest in studying alternatives, we are compelled to emphasize and renew our request that DOE provide a preliminary report detailing which alternatives will be studied, and that this report is made public prior to the completion of the draft EIS study.

The delegation made this same request in an earlier letter dated August 2013, which I noted last summer. DOE’s response to that letter promised that the request would be considered. The delegation’s new letter shows that, once again and despite DOE inaction, New Hampshire’s U.S. senators and representatives remain deeply committed to a permitting process that is fully responsive to the extraordinary public concerns generated by this project, especially the strong interest—reflected in more than 1,400 written comments and extending to the New Hampshire Governor’s officein pursuing alternatives to the current proposal. Northern Pass alternatives are the subject of an ongoing series here at CLF Scoop, the first two installments of which you can read here.

CLF and others have been asking DOE to disclose a detailed plan for the project’s environmental review for three years. It’s a common-sense step in what is a lengthy and highly complex undertaking that must comprehensively assess a 187-mile transmission project and meaningfully incorporate vast amounts of public input. That DOE has not yet agreed to publish a preliminary alternatives report has been profoundly discouraging, especially because there are numerous examples of federal agencies releasing information on alternatives to be studied in an EIS prior to publishing the draft EIS itself—from the I-93 project in New Hampshire to the Northeast Corridor rail planning process to reviews of transmission projects on federal land to DOE’s own historic practice. In this case, CLF and our partners are calling on DOE to allow the public an opportunity to comment on DOE’s alternatives report, to ensure that DOE’s list of alternatives to be studied in detail is as inclusive as federal law requires. 

For not the first time, DOE’s commitment to an open and through environmental review of the Northern Pass project is in question. CLF applauds the Congressional delegation’s repeated efforts to put DOE on a new course that delivers the fair and transparent process that New Hampshire deserves.

Learn more about Northern Pass here or by signing up for CLF’s email newsletter, Northern Pass Wire. For the latest Northern Pass updates, follow me on Twitter.

New Hampshire Environmental Community Calls for Study of Underground Alternatives in Federal Review of Northern Pass

Nov 1, 2013 by  | Bio |  1 Comment »

Earlier this week, seven leading New Hampshire environmental organizations, including CLF, sent a joint letter to the U.S. Department of Energy (DOE) calling for a truly comprehensive and fair environmental review of the Northern Pass transmission project, including a complete analysis of underground transmission alternatives in New Hampshire and other statesYou can read the whole letter here; the signatories’ logos are below.

Yesterday’s announcement of the New England Clean Power Link project in Vermont confirms that underground alternatives are reasonable, economic, and likely to have significant advantages over a project like Northern Pass. It has never been clearer that DOE must carefully analyze these alternatives and weigh them in deciding whether the current Northern Pass proposal is consistent with the public interest. Contrary to the misleading arguments in Northern Pass’s flawed amended permit application, advanced underground transmission technology and potential underground routes warrant detailed study in DOE’s environmental impact statement.

Our other points:

  • DOE should broaden its view of the purpose and need for the project beyond the confines of Northern Pass’s permit application to allow for consideration of the many promising approaches that would also help meet New England’s energy needs.
  • The EIS must include a sound greenhouse gas emissions analysis of the project (something Northern Pass has utterly failed to provide), taking into account both reductions in pollution from the power sources that are displaced by the project and also the emissions of hydropower facilities in Canada.
  • The EIS must include a complete, independent analysis of Northern Pass’s visual impacts, especially on New Hampshire’s many scenic resources. Recent work by the Appalachian Mountain Club confirms that the project would have important and wide-ranging impacts in many viewsheds along its entire route.
  • The EIS must include a full assessment of the project’s impacts on the many conservation lands through and near which the project would run. Our organizations are especially concerned about the impacts within the White Mountain National Forest, where the developer is seeking special authorizations to construct the project.
  • DOE needs to stop making procedural mistakes (such as its tainted process for selecting the contractor team that will be writing the EIS) and conduct the environmental review of the project with meaningful openness, fairness, and impartiality. Our letter sets out some concrete steps that DOE can take now, such as preparing and releasing for public comment a report on which alternatives the EIS will study in detail, well before the draft EIS is completed.

DOE is still accepting public comments on the scope of its environmental review of Northern Pass, but the deadline for comments is next Tuesday, November 5. You can enter your comments directly on the Northern Pass EIS website here. With a comment filed in your own words, you can join New Hampshire’s environmental community in calling on DOE to conduct the rigorous review of Northern Pass and careful analysis of alternatives that New Hampshire deserves.


#NorthernPass #Fail: New Hampshire Speaks Out

Sep 27, 2013 by  | Bio |  Leave a Comment

In 2011, a series of well-attended public “scoping” meetings sent a clear message to the developer of the Northern Pass project: go back to the drawing board. Not long after, Northern Pass announced that it would embark on an effort to make project changes that would address the public’s input, make the project “more acceptable to residents and communities,” and would “earn the favor of the people of New Hampshire.”

Fast forward to today: New Hampshire has lived through the summer rollout of Northern Pass’s “new route”—a slick, million-dollar marketing effort with statewide direct mail, print, radio, television, and Internet advertising, coordinated op-ed and letter-writing campaigns by project-affiliated supporters, a series of trade-show-like “open houses” with dozens of project officials in attendance at each, and lots of corporate blue T-shirts, all repeating the developer’s phony talking points about the project’s supposed energy and environmental benefits and sounding the refrain of “We’ve Listened.”

This week, the public had a chance to respond to the revised proposal at a new round of public “scoping” meetings, which are part of the U.S. Department of Energy’s environmental review of the project’s application for a Presidential Permit to cross the U.S.-Canada border. It turns out that Northern Pass should have listened harder. The week’s takeaway:

#northernpass #fail

At the four meetings—in Concord, Plymouth, Whitefield, and Colebrook—the message was unmistakable: the host communities and New Hampshire as a whole do not want this project.

An overwhelming majority of the nearly 2,000 attendees (an astounding turnout for evening events on two weeks notice) wore hunter orange—the color adopted by the opposition to the project. The audio record (helpfully compiled and edited by radio host Brian Tilton) shows that close to 200 speakers—current and former elected officials, local residents, small business men and women, conservation advocates, youth, and other people from all walks of life—spoke against the project. The public’s reaction followed Governor’s Hassan’s strong comments in Sunday’s Boston Globe taking a clear stand against the current proposal and in favor of pursuing other more innovative energy alternatives.

(There were some 35 supporters of the project who spoke—many of them members of the International Brotherhood of Electrical Workers, which had a sizable presence only at the first meeting in Concord, is unsurprisingly interested in the several hundred jobs that the project could create, and has frequently rallied to PSNH’s side to sustain the utility’s coal plants. Despite supposedly backing “clean energy jobs,” some Northern Pass supporters took time to denigrate wind and solar projects based in New England.)

In my comments at the first meeting in Concord, I focused on the urgent need for the Department of Energy to lead a truly comprehensive, objective, and transparent permitting process, something CLF requested at the first round of scoping meetings and the agency has utterly failed to provide so far:


You can download a copy of my remarks. As CLF did in a filing last week, several speakers called on the Department of Energy to follow its regulations and reject Northern Pass’s Presidential Permit application because it lacks any real alternatives and fails to include important information about the project’s impacts.

Among the many other themes of public comments at this week’s meetings, a few stood out:

In what must be a first for National Environmental Policy Act scoping meetings in New Hampshire, dispatches from the meetings went viral on Twitter (hashtag:: #northernpass) and other social media. I was one of several who “live-tweeted” and shared photos from one or more of the packed auditoriums:

With the scoping meetings behind us, the Department of Energy continues to accept public comments in writing and on its website through November 5. The question now: after Northern Pass failed so miserably to make project changes that would meaningfully increase its public support, will PSNH, Northeast Utilities, the federal government, and New England  “listen” to what New Hampshire stakeholders are telling them about this project? With so many other options for our energy future, it’s long past time.

#northernpass #fail

Concord Northern Pass scoping meeting (photo: Christophe Courchesne)

Egregiously Incomplete: DOE Should Reject Northern Pass’s New Presidential Permit Application

Sep 17, 2013 by  | Bio |  1 Comment »

Today, CLF, the Appalachian Mountain Club, and the Society for the Protection of New Hampshire Forests filed joint comments with the U.S. Department of Energy (DOE) bearing a simple message: the Northern Pass project’s new “amended” application for a federal Presidential Permit once again doesn’t cut it. The application, filed in July, fails to provide the comprehensive and required information that DOE and the public need to evaluate the project. This time, project developer Northern Pass Transmission LLC (NPT) should not get another bite at the apple.

After more than two years of self-imposed delay and thousands of good-faith comments from the public expressing concerns about the project’s impacts and offering a wide range of potential alternatives, project developer Northern Pass Transmission LLC (NPT) has had ample opportunity to right the wrongs in its original, incomplete permit application by fully describing the practical alternatives to the project and its important environmental impacts, including at the project’s power sources in Canada. Instead, as we say in our comments, NPT’s 80-page amended application amounts to a poorly cited legal brief. It fails to include much of the detailed technical and environmental information in NPT’s possession and seeks to avoid thorough and rigorous review of the project and alternatives by dismissively branding each and every alternative to the current proposal unreasonable and impractical.


Enough is enough: no more bites at the apple for Northern Pass (photo credit: flickr/shane o mac)

Why is what’s in NPT’s application so important? For one, the content of the application provides the crucial starting point for DOE’s review of the project and its alternatives. And the application also should provide a set of sound technical and environmental information about the project and its alternatives that the public can reference, evaluate, and hold NPT accountable for. This is especially important in the wake of a saturation public relations campaign that superficially touts the project’s supposed benefits, including a series of “open houses” where project officials control the agenda and won’t answer key questions.

CLF and its partners agree: NPT had its chance to present a revised project, an amended permit application, and a new approach that respected host communities, acknowledged the feasible alternatives to overhead transmission technology outside the original corridor, and made a credible environmental and economic case for increasing imports in the context of the region’s overall energy future and in the face of its affiliate PSNH’s stubborn insistence on continuing to operate uneconomic, dirty coal plants. With its barely changed “new route” and unwavering adversarial stance, NPT blew it.

As CLF’s President John Kassel made clear this summer, the region should pursue a robust regional discussion of the right approach to importing more power from eastern Canada. But without even the solid ground of a complete federal permit application, NPT’s proposal should stop here.

Don’t forget: next week, Show Up and Speak Out at the Final Round of Public Scoping Meetings for Northern Pass, and tomorrow is the deadline for intervening or filing specific comments on NPT’s amended Presidential Permit application.

Show Up and Speak Out at the Final Round of Public Scoping Meetings for Northern Pass

Sep 10, 2013 by  | Bio |  4 Comment »

During the week of September 23, the United States Department of Energy (DOE) has scheduled four additional public scoping meetings in different communities in New Hampshire as part of the scoping process for DOE’s Environmental Impact Statement (EIS) for the Northern Pass transmission project.

As with the well-attended meetings more than two years ago, these new meetings are a vital opportunity to explain your concerns about the project to DOE officials. These meetings are the last in-person moments to influence DOE’s decisions on the scope and content of the draft EIS, including the environmental and social impacts of the project to be considered and the alternatives to be seriously studied. Those decisions will have lasting ramifications as the federal and state permitting processes continue. Here is the schedule:

  • Monday, September 23, 2013, 6–9 p.m., Grappone Conference Center, Concord, NH (map)
  • Tuesday, September 24, 2013, 5–8 p.m, Plymouth State University, Silver Center for the Arts, Hanaway Theater, Plymouth, NH (map)
  • Wednesday, September 25, 2013, 5–8 p.m., Mountain View Grand Resort & Spa, Presidential Room, Whitefield, NH (map)
  • Thursday, September 26, 2013, 5–8 p.m., Colebrook Elementary School, Colebrook, NH (map) (this meeting was moved from a smaller location in W. Stewartstown)

Each meeting will include both an “informal workshop” and a more formal session where the public will have the opportunity to make brief statements. In the 2011 meetings, speakers were limited to 3 minutes. If you want to speak, we advise that you reserve a slot in advance by emailing DOE’s Brian Mills at The formal portion of the meeting will be transcribed by a stenographer, and all public testimony will be included in the official administrative record of DOE’s review of the project.

Even if you aren’t interested in making any remarks in the formal session, please attend and bring your neighbors, friends, and family. The turnout at these meetings is important to the course of the permitting process, and many will be watching to gauge the public’s reaction to Northern Pass’s revised route. Showing up matters!


(photo credit: flickr/Christchurch City Libraries)

You can also weigh in with written scoping comments on DOE’s EIS website. The deadline for these comments is November 5, 2013. (The deadline to file comments with DOE on the amended application and to “intervene” remains September 18.)

What should you say or write? Any reasonable concern or question about the proposed Northern Pass project and alternatives is relevant to the scoping process and will help inform DOE’s decision-making. As a starting point, it may be helpful to review the maps of the project route prepared by Northern Pass Transmission LLC in its amended permit application; both the maps and the application are available at DOE’s EIS website. CLF’s Northern Pass site, our detailed 2011 scoping comments, and three years of our Northern Pass blog posts are also at your disposal. Consider submitting comments on the potential impacts of the project on communities, the White Mountain National Forest, the climate, wildlife, forest resources, wetlands, recreation areas, the renewable energy sector, the local economy, and natural resources in Canada.  And don’t hesitate to tell DOE, once again, that its review of the project needs to be more fair, transparent, and objective than it is now. Note also that Northern Pass’s many rejections of potential alternatives to the project, including in its permit application, aren’t the final word, and DOE must conduct a rigorous review of all reasonable alternatives, including not building the project, and alternative routes and project designs that may have fewer impacts. It’s well settled that an objective and comprehensive analysis of alternatives is an ironclad legal requirement and, indeed, the heart of the federal environmental review of the project.

Show up and speak out!

Northern Pass Update: New Opportunities to Make Your Voice Heard

Aug 30, 2013 by  | Bio |  2 Comment »

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.

Recent Developments

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.


NPT rendering of Northern Pass project from the Rocks Estate in Bethlehem, NH

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.)

Get Involved

If you are concerned about Northern Pass, you have three immediate opportunities to weigh in on the project and its amended permit 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 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 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: