Amid new scrutiny, it’s time for Massachusetts to reckon with the elephant in its climate plan (photo credit: flickr/David Blackwell)

The 5 million ton elephant in Massachusetts’s nation-leading climate action plan – the oversold and overstated greenhouse gas emissions reductions from new imports of Canadian hydropower comprising more than 20% of the state’s goal – is too big to ignore. That’s why it’s encouraging that the plan’s misplaced reliance on the Northern Pass transmission project is receiving new scrutiny.

Last December, CLF identified a significant problem with Massachusetts’s “Clean Energy and Climate Plan for 2020”: it adopted and relied on Northern Pass’s sales pitch that the project will reduce carbon dioxide emissions by 5 million tons annually and then claimed all those emissions reductions for Massachusetts. After examining the basis for the 5 million ton figure, we concluded that – no way around it – the figure was just wrong; it was calculated on the false assumption – belied by Hydro-Québec’s own data – that imported hydropower has no greenhouse gas emissions.  The way Massachusetts was relying on Northern Pass was dubious for other reasons, including the unfairness of Massachusetts claiming all the benefits of a project that will not be located in the state and the fact that there is no concrete commitment regarding how much Northern Pass power Massachusetts electric customers will actually receive.

In February, the problem was confirmed in a technical report (PDF) commissioned by CLF and authored by Synapse Energy Economics, which found that hydropower facilities, especially new projects being built in Québec to supply new imports into New England, have substantial greenhouse emissions – emissions that for several years after construction can be comparable to the natural gas power that Northern Pass would replace.

Last month, Massachusetts think-tank MassINC released an independent analysis (PDF) of Massachusetts’s progress in meeting its ambitious emissions reduction goal – 25% below 1990 levels by the year 2020. The conclusion: Massachusetts is making great strides in some areas, but needs to redouble its efforts if it intends to achieve the goal. One of the biggest uncertainties: the Massachusetts climate plan’s reliance on new imports of Canadian hydropower through Northern Pass.

MassINC’s new report signals, as CLF has argued, that Massachusetts must look elsewhere to secure sufficient emissions reductions by 2020. The MassINC report makes the critical point that it is not up to Massachusetts whether the Northern Pass project is built – and there are many reasons to doubt that it ever will be – not the least of which are the extensive permitting processes and the committed and well-founded community opposition that the project must overcome. Citing Synapse’s findings on the greenhouse gas emissions of hydropower and the higher emissions associated with new hydropower facilities, the MassINC report suggests that any reliance on new imports as an emissions reduction strategy requires a credible, scientifically sound accounting of the targeted reductions, including whether and to what extent the power will come from new hydropower projects. Massachusetts needs to temper its enthusiasm for additional hydropower imports with the same scientific rigor and attention to detail reflected in the Patrick administration’s proposed regulations for biomass power.

The MassINC report is making waves, earning the lead, front page story recently in the Boston Sunday Globe and media coverage throughout the state. Consistent with the MassINC report, CLF does not rule out the possibility that new hydropower imports – if they have minimal environmental and community impacts on both sides of the border, avoid undermining local renewable and energy efficiency, displace our dirtiest power, and provide verifiable emissions reductions – could play a constructive role in a cleaner energy future for the region, particularly when considered over the long term.

But it’s time for the Patrick administration to reconsider its unfounded confidence that Northern Pass is some kind of clean energy panacea that will deliver a fifth of all needed emissions reductions by 2020. The science is clear: it’s not.

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.

While much of Boston was distracted by the approaching holidays, public health and the environmental justice communities of Roxbury / South End scored a victory last Friday, December 23^rd, when Secretary Sullivan issued his final decision to deny BU’s request to begin high level research at BU’s National Emerging Infectious Disease Laboratories (NEIDL) until a full risk assessment is reviewed by EOEEA.

This decision brings to a close one chapter in a larger, protracted debate regarding acceptable levels of risk for this project, otherwise known as the BU Biolab. Biodefense research conducted at the lab would bring highly contagious, rare and lethal pathogens, such as ebola, to densely populated urban neighborhoods. Members of local communities have expressed strong opposition to the siting of this facility near their homes and schools.

Meanwhile, BU has failed multiple times to assess and justify the risks associated with the NEIDL as required by state and federal statutes. Their assessments have repeatedly been subject to criticism for the poor quality of their analysis. Despite this, BU requested a waiver to proceed with operating the lab – a request that applied to all proposed research for the NEIDL except that which would occur in Biocontainment Safety Level 4 (BSL-4) labs, including BSL-3 research. CLF and other opponents of the lab strongly opposed this request.

Secretary Sullivan’s final decision denies BU’s request to begin BSL-3 research before a full risk assessment is reviewed by EOEEA. We welcome this decision, and consider it to be a victory for the security of the local community and the integrity of the legal process. As stated in joint comments filed last week, we support this decision for the following reasons:

1) It’s the law. The Secretary’s decision is in line with the Superior Court and Massachusetts Supreme Judicial Court rulings that require the EOEEA to fully review risk assessments for BSL-3 and 4 research at the NEIDL.

2) It’s too risky not to understand the risks. Careful review and oversight of this facility is necessary given BU’s poor track record of reporting accidents in a timely manner and communicating with the community on this issue.

3) The public not only should participate – they are required to. The EOEEA Environmental Justice Policy requires enhanced state review and public participation opportunities because of the proposed facility’s location in Roxbury/South End.

What You Can Do:

NIH’s Blue Ribbon Panel will come to Hibernia Hall in Roxbury on February 16^th to hold a public meeting and hear comments on NIH’s draft risk assessment for the NEIDL. CLF will post the time and other details for the public meeting here when they become available. Mark your calendar and join CLF and its partners in seeking to ensure that this facility does not introduce unnecessary risk to an already overburdened environmental justice community.

Protestors at BU Biolab. Courtesy of Steph PS @ flickr. Creative Commons.

There’s a common saying that if you can’t measure it, you can’t control it. Leaders of Boston University’s proposed National Emerging Infectious Diseases Laboratories (NEIDL) – known as the BU Biolab – in the densely populated urban environmental justice community of Roxbury/ South End, have asked the state to waive required review of their plans to build a lab involving rare and lethal pathogens even though their prior risk assessments were found inadequate multiple times. In other words, they want to build a risk laden facility without accountability to the public. We oppose the grant of this request.

We Support Secretary Sullivan’s Decision in Favor of Thorough Review

Today advocates in the fight against the Biolab filed joint comments with Secretary Sullivan supporting his draft decision which, if adopted as final later this month, will deny BU’s request to begin high level research before a full risk assessment is reviewed by EOEEA. You can read a copy of our comments here, and find the draft decision here.

Background on the Biolab

The facility would focus its research on biological agents used in acts of bioterrorism – a mission the community fears will bring biodefense research on highly contagious pathogens to their densely populated urban neighborhoods.  Members of the Roxbury/South End communities have expressed vocal opposition to the siting of this facility near their homes and schools.

Biocontainment Safety Level ratings, established by the federal Centers for Disease Control and Prevention, increase from 1 to 4 based on the danger associated with research on different biological pathogens and mandate increasing levels of physical protection to prevent a public health crisis in the event that a pathogen leaves the lab (e.g. through transmission from an infected lab worker, an escaped animal subject, or an outbreak resulting from a natural disaster or a malevolent act at the lab). BU’s NEIDL would include research in each of the four Biocontainment Safety Levels.

Research in labs designated as Biocontainment Safety Level 4 (BSL-4), the highest level, includes rare and lethal pathogens, such as ebola. According to BU’s waiver application to EOEEA, their BSL-4 research would involve pathogens that “cause diseases that are usually life-threatening” and are spread through the air or “an unknown cause of transmission.” BU has also quoted the U.S. Department of Health and Human Services as stating that pathogens appropriate for research in BSL-3 laboratories “cause diseases that may have serious or lethal consequences” and are transmitted through the air.

BU’s Multiple Failures

BU has attempted – multiple times – to explain and justify the risks associated with the NEIDL as required by state and federal statutes. Each time, they have failed and been subject to criticism for the poor quality of their analysis.

Their risk assessments (which must satisfy requirements under the Massachusetts Environmental Policy Act and the National Environmental Policy Act) have been found to be insufficient and not credible by the EOEEA and the Massachusetts Supreme Judicial Court, as well as the National Research Council. Each of these failures to acknowledge the risks associated with the NEIDL has alienated the community, resulting in a marked distrust of BU.

BU has now partially completed its third attempt to justify the risks associated with the NEIDL. This time the risk assessment is being conducted by the National Institutes of Health (who provided significant federal funding for the project) and their private consultant, Tetra Tech.

BU’s Request to Limit Review of Risks

Concurrently with their third attempt to justify the risks associated with the NEIDL, BU filed a written request asking Secretary Sullivan to waive the legal requirement for EOEEA review of certain research at the lab. BU’s request applied to all proposed research for the NEIDL except that which would occur in BSL-4 labs.  CLF and other opponents of the lab strongly opposed this request. A waiver from full EOEEA review would deny the Commonwealth the opportunity to ensure that the risks to the surrounding environmental justice community from this facility had been fully considered.

On December 2, in his draft waiver decision and Certificate on Notice of Project Change, Secretary Sullivan allowed lower level research (BSL-1 and 2) to proceed but stated that EOEEA is “legally barred from acting on [BU’s] waiver request for BSL-3 level research until I am able to independently review the risk assessment for the contagious pathogens proposed for study by BU at the Biolab.”

Today CLF joined the Lawyers Committee for Civil Rights and Anderson & Kreiger, a law firm representing the Safety Net, a community group led by local activist Klare Allen, and other affected community members, in submitting written comments to Secretary Sullivan calling upon him to finalize his draft decision denying a waiver of EOEEA review for BSL-3 research at the NEIDL, and reminding him of his charge under the EOEEA Environmental Justice Policy to ensure that this review process provides enhanced public participation opportunities.

As we state in our comments, we thank the Secretary for recognizing that the NEIDL will involve “research on extremely contagious biological agents that could pose serious harm to an already compromised Environmental Justice community.”

What You Can Do:

• A final decision from Secretary Sullivan on BU’s waiver request is expected on December 28. Stay tuned for news about that decision here. A final draft of NIH’s risk assessment is expected to be issued by NIH in the next few months.
• NIH’s Blue Ribbon Panel will come to Hibernia Hall in Roxbury on February 16^th to hold a public meeting and hear comments on NIH’s draft risk assessment for the NEIDL.  CLF will post the date, time, and other details for the public meeting here when they become available.  Mark your calendar and join CLF and its partners in seeking to ensure that this facility does not introduce unnecessary risk to an already overburdened environmental justice community.

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.