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

Sep 17, 2013 by  | Bio |  Leave a 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)

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 Brian.Mills@hq.doe.gov. 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!

public-scoping-meeting

(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.

northern-pass-update

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 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:

Northern Pass Developers Refuse to Face Facts about Hydropower Emissions

Apr 4, 2012 by  | Bio |  Leave a Comment

The American developers of the Northern Pass project are misleading the public about the project’s most touted environmental benefit (without which they “wouldn’t be doing this”): reducing New England’s greenhouse gas emissions. Presented with clear, unambiguous evidence that the current proposal would not meaningfully reduce emissions and that their public relations campaign is trading in falsehoods, the developers have done nothing to correct the record or provided any substantive response to the evidence.

In mid-February, CLF released a report on the science regarding large-scale hydropower’s emissions of greenhouse gases, the pollutants that are driving climate change. The conclusion: large-scale hydropower projects, especially new facilities, have substantial greenhouse gas emissions that, in their first years of operation, are equivalent to emissions from modern natural gas power plants.

This conclusion means that the proposed Northern Pass project, which would import up to 1,200 megawatts of new Canadian hydropower into New England and displace power from domestic natural gas plants, would not meaningfully reduce greenhouse gas emissions, as the developers are claiming.  CLF’s report also demonstrated that the assumption at the heart of the developers’ claim that the Northern Pass project would reduce emissions by 5 million tons per year – that Canadian hydropower has no greenhouse gas emissions – is unequivocally false.

CLF sent a copy of the hydropower emissions report to Northern Pass Transmission LLC (NPT). In our transmittal letter, we made clear that the science summarized in the report (some of which was included in NPT’s own regulatory filings) clearly contradicted NPT’s marketing claims and urged NPT to:

  • correct the regulatory and public record by retracting and withdrawing all NPT prior statements that hydropower results in no emissions of greenhouse gases and that the Project will reduce carbon dioxide emissions by any specific amount, and
  • refrain from making any claims regarding carbon dioxide emissions reductions associated with the Project unless and until those reductions are substantiated in a new technical analysis subject to public and permitting agency review.

To date, NPT has taken neither step. The false “no emissions” canard and the unsupported claim of 5 million tons of annual emissions reductions from the project are still prominent fixtures at NPT’s MyNewHampshire.com:

"No greenhouse gases" (source: http://www.northernpass.us/pdf/ads/Jack.pdf)

NPT spokesman Martin Murray did post a non-responsive comment on CLF’s website, to which I responded in detail here. On its own website, NPT then heralded a Hydro-Québec press release responding to the report, and I explained here why the press release neither reflected a close reading of the report nor challenged the report’s fundamental conclusions but, instead, underscored Hydro-Québec’s position that the major promise of new hydropower imports was as a long-term replacement for dirty, costly coal power plants like New Hampshire’s own Merrimack and Schiller Stations – not natural gas.

Where do NPT’s non-responses leave us? Unfortunately, NPT seems poised to continue on with its false and misleading public relations campaign and has shown no interest in an open, honest debate. CLF will continue to use all the tools at our disposal to ensure that the public and decision-makers are fully aware of all the issues associated with the Northern Pass proposal. 

You can support our work by becoming a CLF member and also by telling the permitting agency now reviewing the Northern Pass proposal to consider hydropower’s greenhouse gas emissions – and all the other impacts of Northern Pass power in Canada – as part of the agency’s environmental review – click here to take action.

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.

ACTION ALERT: Tell the Department of Energy – Consider the Impacts of Northern Pass Hydropower!

Mar 23, 2012 by  | Bio |  1 Comment »

Seeking the Current filmmaker Nicolas Boisclair on the bank of Québec's Romaine River (photo courtesy Chercher le Courant)

This month, Seeking the Current wowed audiences across New Hampshire with the sublime beauty of Québec’s Romaine River – a wild, natural wonder that will essentially be destroyed by a new complex of hydropower projects, now under construction.  This complex is only one part of Hydro-Québec’s ongoing building boom – the keystone of the Canadian utility’s aggressive strategy to increase exports to the United States. The film also showed filmgoers that there are better, cheaper alternatives to new hydropower, including wind, solar photovoltaic, solar hot water, biogas, and investments in energy efficiency.  If these alternatives were scaled up and put in place throughout the province, Québec could still export more power to the United States – but without constructing new dams and reservoirs.

During the discussions after the film (one of which you can watch here), we heard the same question again and again – what can we do here in New England? The filmmaker Nicolas Boisclair observed that Hydro-Quebec’s strategy relies on opening new “doors” to New England and other export markets – like the Northern Pass transmission project. That’s another reason why CLF sees the permitting process for Northern Pass as so important – it is our opportunity to scrutinize whether we should open the door and on what terms, given all the impacts of the Northern Pass transmission project and the new Canadian hydropower the project makes possible.  And there is still time for all of us to tell the lead federal permitting agency for Northern Pass – the U.S. Department of Energy (DOE) – to do its job by fully considering the impacts of Canadian hydropower.

Understanding Northern Pass’s power source is fundamental to understanding Northern Pass, especially with the developers of the project touting the environmental benefits of Canadian hydropower at every opportunity. PSNH President Gary Long even has said “we wouldn’t be doing” Northern Pass if it didn’t provide a “greener, cleaner energy future.” But when it comes to scrutinizing all the impacts of that same hydropower in the permitting process, the developers change their tune, arguing that the impacts of Hydro-Québec’s strategy to build more hydropower projects and export more power to the northeastern United States are “beyond the reach of” federal law.

On this point, the developers are wrong. Federal law requires that all direct and indirect effects of the Northern Pass project be analyzed and considered as part of DOE’s environmental review. In the words of the Council on Environmental Quality – the office that oversees all federal environmental reviews – “agencies must include analysis of reasonably foreseeable transboundary effects of proposed actions in their analysis of proposed actions in the United States.” The impacts of hydropower in Canada – so stunningly documented in Seeking the Current and so much more worse for the climate than the misleading story Northern Pass developers like to tell – are “reasonably foreseeable” consequences of the Northern Pass project, and the Department of Energy must consider them, alongside all the potential impacts of building a large-scale transmission line through New Hampshire. CLF made this clear in our comments to DOE a year ago, but it is critical that DOE hear from as many voices as possible.

Please join CLF in calling on the Department of Energy to consider the impacts of Northern Pass hydropower in Canada.  With only a few clicks, you can take action here.

Join CLF Next Friday March 9 for a Special Webinar on Importing Canadian Hydropower

Mar 1, 2012 by  | Bio |  Leave a Comment

With Northern Pass and other new transmission projects on the horizon, CLF and other leading New Hampshire environmental organizations are presenting a special free webinar on what it really means for New England to import more hydroelectric power from Canada.

The webinar will be next Friday, March 9, 2012, 2:30 to 4pm EST. Click here to register. All you’ll need is a computer and an Internet connection. Please join us, and spread the word to friends, family, and colleagues. The webinar is sponsored by CLF and our friends at the Appalachian Mountain Club, Conservation New Hampshire, The Nature Conservancy in New Hampshire, and the Society for the Protection of New Hampshire Forests (SPNHF). 

A scene along the Romaine River from Seeking the Current (copyright Chercher le Courant)

The idea is to provide an accessible summary of the environmental and energy implications of imports, including the often-overlooked impacts of the new hydropower developments in Canada that will supply the power. One of the key questions is what new imports will really mean for the climate, and I’ll explain the findings of a recent report commissioned by CLF on the greenhouse gas emissions of hydropower. As we’ve often pointed out, whether and how to import more hydropower from Canada is a critical issue for the entire region’s energy future. And it’s not just about New Hampshire and Northern Pass — just last week, the developer of the Champlain Hudson project in New York announced that it is moving forward with a revised proposal for an underwater and underground transmisssion line between Canada and New York City that will have the support of state officials, municipal governments, and environmental groups.

During the webinar, you’ll hear from me, and also from Tom Irwin, CLF Vice-President and CLF-NH Director; Ken Kimball, AMC Director of Research; and Will Abbott, SPNHF Vice President for Policy and Land Management.

The webinar will feature a special guest appearance by Québecois filmmaker Nicolas Boisclair, who will be in New Hampshire this month for a series of screenings of his documentary film, Seeking the Current, which shines an unsparing light on Hydro-Québec and its ongoing $8 billion hydropower project on the Romaine River. We’ve put all the details on the screenings (and the webinar too) at this link.

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/northern-pass), and take a look at our prior Northern Pass posts on CLF Scoop.

Latest Research: Northern Pass Worse for the Climate than Advertised

Feb 14, 2012 by  | Bio |  10 Comment »

Hydro-Québec hydroelectric projects recently commissioned or under construction (Source: Quebec Ministry of Natural Resources and Wildlife)

Reducing the region’s emissions of greenhouse gases is supposedly the Northern Pass project’s marquee public benefit, its raison d’être as they say in Québec. But would the Northern Pass project do the job?

The answer appears to be: probably not any time soon. Today, CLF is releasing a ground-breaking new technical report regarding the greenhouse gas emissions of Canadian hydropower. The conclusions of the report show that large-scale hydropower, especially new reservoirs, is worse for the climate than Northern Pass’s developers are claiming, with substantial greenhouse gas emissions that are comparable to those of modern natural gas-fired power plants. The current Northern Pass proposal substitutes hydropower for natural gas in New England’s energy mix, meaning that the project won’t reduce emissions by much if any, especially in the near term.

Authored by Synapse Energy Economics, the technical report released today, Hydropower Greenhouse Gas Emissions: State of the Research, is an independent survey of the recent science regarding the greenhouse gas emissions of hydropower. The science is clear that the reservoirs behind hydropower dams emit greenhouse gases, relative to the forests and wetlands they flood (which often take greenhouse gases out of the atmosphere). Overall, reservoirs in Québec emit more greenhouse gases over the course of their lives than renewables like wind, solar, and run of river hydropower.

A crucial finding of the report concerns new reservoirs. In the first several years after a reservoir is dammed, large amounts of newly inundated organic material decompose, emitting carbon dioxide that diffuses through the water into the atmosphere. As a result, a reservoir’s net emissions in its early years are very high – starting out even higher than emissions from a natural gas power plant per unit of power generated. This effect is evident in recent, rigorous analyses by several teams of scientists, based on data collected at Hydro-Québec’s Eastmain 1 reservoir in northern Québec. This reservoir is the very same project that Northeast Utilities’ CFO testified under oath last year would be the primary, if not exclusive, source of Northern Pass’s power. Even when their emissions are projected over their lifetimes, newly flooded Canadian reservoirs may emit nearly two-thirds of the greenhouse gases emitted by natural gas power plants. By contrast, reservoirs emit only about 20% of the greenhouse gases emitted by typical coal-fired power plants.

This conclusion is the death knell for Northern Pass Transmission, LLC’s (NPT) claim that the current Northern Pass proposal would reduce greenhouse gas emissions by up to 5 million tons. We explained the claim’s key flaw – the report on which it is based erroneously assumes that hydropower has no greenhouse gas emissions – back in August. In light of today’s report, CLF is calling on NPT and its partners NU, NSTAR, and PSNH to stop citing that erroneous number and to withdraw all marketing materials for the Northern Pass project that state or imply that Canadian hydropower has no or minimal greenhouse gas emissions. Hydro-Québec is building new hydropower projects that are intended to facilitate new exports to the northeastern United States. To the extent that the prospect of exports is driving the construction of new reservoirs, Northern Pass and projects like it will be responsible for those reservoirs’ emissions and also their other adverse environmental impacts. And if, as the developers’ analysis concluded, the power to be displaced by imports through Northern Pass is overwhelmingly from natural gas plants, the emissions from a succession of new reservoirs in Canada may replace – perhaps completely for a period of time – the emissions of displaced natural gas power. In that scenario, the Northern Pass project would do little – or even nothing – to reduce greenhouse gas emissions, at least in the near-term.

The report makes another critical point about a different kind of displacement that could occur with Northern Pass. According to a recent study, stepping up Hydro-Québec’s exports to the United States may actually decrease its exports to other provinces in Canada, where the need for fossil fuel-fired power then increases, resulting in additional emissions. Those emissions may cancel out any reductions from displaced power in the United States. This effect is a potential blind spot that needs to be considered and analyzed as part of the public review of any new imports.

The report’s findings are important information regarding the environmental impacts of the project that the U.S. Department of Energy must consider as part of its review of Northern Pass’s application for a Presidential Permit. For that reason, earlier today, CLF submitted the report to DOE along with Synapse’s analysis of the potential effect of Northern Pass on the regional market for renewable energy.

To CLF, the report suggests that new imports could be part of the region’s climate strategy if imports:

  • displace dirty power, like project sponsor PSNH’s uneconomic, subsidized power plants, to achieve a meaningful net reduction in greenhouse gas emissions without increasing the use of fossil fuel-fired power plants in Canada;
  • support – rather than undermine – local renewable projects and energy efficiency efforts in New England; and
  • have minimal impacts on the environment and communities on both sides of the border.

PSNH is in a unique position to take its coal units offline, in conjunction with its potential power purchase agreement with Hydro-Québec that is supposedly in the works. Instead, PSNH is marching on with its broken coal-based business model at great cost to New Hampshire consumers and the environment. Unless the proposal changes, the Northern Pass project does not deliver on the developers’ claims and will not advance a cleaner energy future for New England.

Northern Pass: The 5 million ton elephant in Massachusetts’s climate plan

Dec 1, 2011 by  | Bio |  Leave a Comment

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.

What the Keystone XL decision should mean for Northern Pass

Nov 17, 2011 by  | Bio |  Leave a Comment

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.

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