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.

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!

(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!

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:

• Submit comments to DOE on Northern Pass’s amended application.

The application is a lengthy document with additional information on the project and a number of exhibits, but much of the proposal is exactly the same as the proposal that has been on the table for almost three years. This is an opportunity to tell DOE, for example: what your concerns are with the project, what you think of the changes to NPT’s proposal, what you think is missing from the application, whether NPT’s discussion of alternatives is adequate, and whether DOE should require NPT to submit more information for public review before the permitting process continues. You may file comments by sending them to Christopher.Lawrence@hq.doe.gov and then sending a hard copy of the comments to Christopher Lawrence, Office of Electricity Delivery and Energy Reliability (OE-20), U.S. Department of Energy, 1000 Independence Avenue SW., Washington, DC 20585.  The deadline for submitting comments is September 18.

Regardless of this deadline, you can continue to file “scoping comments” on DOE’s environmental review of Northern Pass at http://www.northernpasseis.us/. DOE has not announced a deadline for those comments.

• Request intervener status in the DOE permitting process.

You should consider filing for intervener status if you want to play an ongoing role in the process. Landowners, residents of affected communities, and interested organizations, as well as local communities and municipal boards should consider filing for this status, if they didn’t do so in 2010 (a list of those that did is here). To give you an idea of what an intervention filing looks like, take a look at CLF’s filing from 2010 (20 MB PDF). Another simpler example is the 2010 filing of the North Country Council.  The requirements are spelled out in federal regulations (18 C.F.R. 385.214) and DOE’s Federal Register notice. The deadline for filing for intervener status is September 18.

• Attend a developer-sponsored open house.

This is your chance to speak your mind and ask hard questions. Let us know what you hear! The next open house is in Concord on September 4, and more are scheduled. Here are some suggestions:

• These open houses seem to be targeted at residents and landowners; project representatives have maps and computer programs to show where the project would be located. Find out how the project would affect your town or places that are special to you, and tell the representatives what you think about the impacts.
• Ask project representatives to explain if and by how much the project will reduce your energy bill, especially if you are a PSNH customer.
• Ask why they continue to use an estimate of the project’s climate benefits that is completely untrue.
• Ask why the project is not proposing to use the new imports to phase out PSNH’s dirty, costly coal plants.
• Ask why siting a non-reliability transmission project in roadbeds owned by unwilling landowners is different from using eminent domain.
• Ask why underground transmission technology is not an option for more of the project.
• Ask why the proposed jobs fund contributions are less than 1% of the project’s annual profits.
• Insist that project representatives follow up and provide information and proof in response to your questions in writing.
• Keep in mind that these open houses are not part of the public review process for the project. They are a public relations gesture and a showcase for NPT to get its message out. Whether or not they reflect any form of honest engagement with the public remains to be seen.

There will be many future opportunities to participate in the federal and state permitting processes for Northern Pass, including at additional scoping meetings for the federal environmental review, which have not yet been scheduled but will likely be later this fall. We’ll keep you posted. UPDATE: DOE has announced the final round of public scoping meetings for the project’s environmental review for the week of September 23. More on those meetings here.

* A sampling of the many thought-provoking pieces authored by concerned citizens this summer:

• Lee Sullivan, Northern Pass Project Power Is Not Needed (Foster’s Daily Democrat)
• Nancy Martland, Unneeded Power Line Would Scar New Hampshire (Hartford Courant)
• Dolly McPhaul, How Dare They? PSNH Exploiting NH (Nashua Telegraph)
• Kathy Sullivan, Northern Pass Numbers Do Not Add Up (Manchester Union Leader)
• Fergus Cullen, Northern Bailout – PSNH, Public Assets and Private Profits (Manchester Union Leader)
• Terry Cronin, Psst, PSNH, Why Not Join the 21st Century? (Concord Monitor)

(photo credit: flickr/Takashi H)

Like PSNH’s zombie talking points about the Northern Pass project, the company has once again repeated a baseless and misleading claim—this time in a vain hope of sustaining its failing coal-fired business model. Once again, the cold, hard facts belie PSNH’s claim of a $700 million savings to its customers over the last decade.  PSNH customers have lost hundreds of millions of dollars since 2003.

In early 2012, PSNH vigorously opposed a bill that would have required it to sell its power plants, where the market would be deciding their fates. It proclaimed, as it has for a decade, that divesting would be the wrong choice for PSNH customers and New Hampshire residents. A PSNH executive told legislators that “PSNH customers have saved more than $700 million over the last decade because our energy was priced below the market price for most of that time.”

PSNH has repeatedly touted this $700 million savings—most recently in a statement on its website last month—but it has never substantiated the figure. PSNH might have compared its rates to the average spot rates on the wholesale market, or it might have conducted some other irrelevant calculation. What is certain is that PSNH has never offered the most relevant and useful calculation, which is: How much would PSNH customers have paid for electricity if they had been served by a different New Hampshire utility for the past decade? The answer is, less. Hundreds of millions of dollars less.

Using data from PUC dockets, we compared the default service rates for small/residential customers of PSNH and those of Granite State Electric Company (GSEC). For PSNH, all figures were taken directly from PUC filings. For GSEC, figures from 2008 to 2013 were taken directly from PUC filings, and the average yearly rates from 2003-2008 were estimated based on a graph from the PUC Staff Report on Market Conditions, Default Service Rate, Generation Ownership and Impacts on the Competitive Electricity Market, which we explained here. By multiplying the cost differential of the PSNH and GSEC rates by the total kilowatts of electricity PSNH has delivered each year to its customers, we estimated that PSNH customers would have paid about $400 million less if they had been served by GSEC.

PSNH has already spent $40 million buying up land in the North Country for its Northern Pass route—the same amount its customers have lost on average every year. That average yearly loss has jumped to over $100 million/year since 2009.  That’s like buying a smartphone for every single residential PSNH electric supply customer every year, and then throwing them all in the Merrimack River.

PSNH could have purchased power competitively from the market like GSEC, and it could have had the same or even lower rates. As PUC Staff point out in their report: “If PSNH were to no longer own its generation fleet, and PSNH were then to procure its default service requirements as do the other New Hampshire distribution utilities . . . PSNH’s default service rate would more closely mirror prevailing market prices.” But instead it chose to continue running its inefficient fossil plants, forcing New Hampshire ratepayers to subsidize dirty, inefficient energy sources along with mounting costs for PSNH’s failed investments in its power plants, including the astoundingly costly $422 million scrubber project at Merrimack Station.

The good news is that every PSNH customer can choose to escape these costs and not to support these dirty, inefficient plants. 90,000 residential customers have already fled PSNH supply to competitive suppliers, who offer lower rates for cleaner power. This mass migration moves us closer every day to the clean, affordable energy future New Hampshire deserves.

As the PUC Staff Report predicts, the cost of this lost opportunity for PSNH customers will likely grow exponentially in coming years as PSNH’s coal units become increasingly inefficient. No matter how PSNH spins the numbers, the truth blares louder every day: By holding on to its dirty coal plants, PSNH is sucking millions of dollars out of New Hampshire ratepayers and denying the state the clean energy, public health, and economic benefits of a post-coal Granite State.

(photo credit: flickr/macwagen)

With last month’s Northern Pass route announcement and last week’s filing of an amended application for a Presidential Permit, Northeast Utilities and PSNH have repackaged and repeated the very same arguments for the project that have filled air waves and op-ed pages throughout New England for nearly three years. We keep hearing the same sales pitch—cleaner air, a more reliable grid, economic prosperity, low-cost energy—with the same numbers: 5 million fewer tons of carbon pollution, 1,200 jobs, and millions in energy savings and tax revenue.

From a distance, the claims look real enough; on closer inspection, it becomes clear that they were born in a long-gone energy landscape and are aggressively deceptive. And they live not only in Northern Pass’s marketing materials, but in the disseminations of Northern Pass’s cadre of PSNH-aligned supporters, such as this recent op-ed by an avowed clean energy opponent who worked for a group that calls climate change “pseudo-science.”

CLF and others have been examining and debunking these talking points for a long time. But like zombies, they keep coming back. And there is perhaps no uglier member of Northern Pass’s living dead than the claim that Northern Pass will reduce carbon pollution by up to 5 million tons per year.

The number is an estimate of the carbon dioxide emissions from the typically natural gas power that Northern Pass imports would displace in our regional energy mix, based on a 2010 market modeling report by an economic consultant hired by Northern Pass—a report that, despite numerous references to it in the project’s amended application, no longer appears on Northern Pass’s website but is available here (25 MB PDF). The estimate assumes four things:

Assumption No. 1: Northern Pass power would not result in any carbon dioxide emissions. (See pp. 5 and 34 of the report.)

This is unequivocally wrong. Scientific research conducted by Hydro-Québec scientists and published in peer reviewed journals says just the opposite. The science confirms that, by flooding vast areas of boreal forests, new large-scale hydropower facilities have net greenhouse gas emissions (from the decomposition of flooded biological material, the elimination of forest carbon “sinks,” and other sources) that may initially exceed those of natural gas power plants and that, despite declining and producing fewer net greenhouse gas emissions than natural gas over time, may continue at meaningful levels even over the long term. Northern Pass’s continued “zero-carbon” assumption is dishonest and cynical, especially given the fact that Northeast Utilities has submitted summaries of the very same research findings on hydropower emissions to regulatory authorities and has steadfastly refused to change its marketing materials despite CLF’s effort to point out the error.

Assumption No. 2: Over the next ten years, New England’s energy market will look like government forecasts predicted in 2010. (See pp. 23-24 of the report.)

Northern Pass’s 5 million ton estimate is highly dependent on outdated modeling of an energy market that no longer exists. Its consultant report was prepared three years ago—in 2010—with U.S. Energy Information Administration forecasts of energy commodity prices, including natural gas prices approaching $7 per million cubic feet by 2022. The forecast price of natural gas is crucial to predicting how Northern Pass power will affect New England’s energy market because that price helps determine the market price of electricity in New England. Since 2010, domestic natural gas supplies have driven down prices, and the EIA’s forecast has changed dramatically, now estimating that average prices won’t crack $5 until 2026. (The spot natural gas price today is well below $4; the 2010 projection for 2013 was $6.13.) While CLF and many other stakeholders are deeply concerned about proposed long-term investments in natural gas (and their climate impacts), there is no denying that the fuel’s role in the region’s energy market is different than what was predicted in 2010.

In addition to lower power prices in New England, the report failed to account for the availability of an additional path for Hydro-Québec to export its power—the Champlain Hudson Power Express—which won approval from New York officials earlier this year and is in the process of obtaining federal permits.

All this means is that Hydro-Québec will likely sell less power into New England than previously estimated, replacing (by Northern Pass’s own logic) less natural gas power and its associated pollution.

Assumption No. 3: Hydro-Québec will continue to build more hydropower facilities, including the Romaine River dams that are under construction, which will facilitate additional exports to the United States. (See pp. 2 and 28 of the report)

The report on which Northern Pass’ claimed 5 million ton greenhouse gas reduction is based explains that “[i]n reality, the additional transmission capacity provided by [Northern Pass] could lead to additional development of resources to support exports from Québec….” In fact, the 5 million ton estimate is only that high because it includes emissions reductions (which are inflated for the reasons identified above) that will happen if Hydro-Québec develops new hydropower projects and as a result has more surplus energy available than it does today. (If not, the report itself predicts emissions reductions of only about half the 5 million ton estimate.) The assumption suggests that Hydro-Québec will rely on a succession of new projects –the Eastmain-Rupert River complex just completed, the Romaine River complex under construction, and the Magpie and Petit-Mécatina complexes that are in Hydro-Quebec’s strategic plan—to feed exports to New England.

With this context, the 5 million ton estimate is even more unrealistic because the short-term greenhouse gas emissions of new projects are worse than older facilities. The assumption of new projects in Canada is noteworthy as well because, while consistent with sworn testimony by a Northeast Utilities executive about the source of Northern Pass power, it is directly at odds with Northern Pass’s repeated refrain that Northern Pass power will merely be excess “system power” from Hydro-Québec and won’t require the construction of new hydropower facilities. (See p. 6, footnote 1 of the amended application.)

Assumption No. 4: There won’t be any greenhouse gas emissions associated with the energy that Québec’s other neighbors may need when Northern Pass comes online and more Hydro-Québec power flows to New England.

Where would Hydro-Québec sell its energy without Northern Pass, and what power sources other than Hydro-Québec power will those places use if Northern Pass is built? Whether Northern Pass has any climate benefit depends on the answers. The report’s estimate of increased Hydro-Québec power sales into New England predicts that New England will get power that would otherwise flow to New York and Ontario. (See p. 27 of the report.) In both markets, natural gas is the marginal fuel, meaning that it both sets energy prices and tends to be the power source that makes up for unavailable sources. In other words, it would be reasonable to assume that natural gas power plants in New York and Ontario will run more if Northern Pass is built and shifts Hydro-Quebec’s exports to New England. Northern Pass’s 5 million ton greenhouse gas reduction estimate wrongly assumes that other regions’ replacement power won’t have any carbon emissions—in fact, it doesn’t address this critical issue at all. Because climate change is a global phenomenon, what we have here looks like a shell game: the supposed climate benefits of Northern Pass from displacing natural gas power in New England could very well be cancelled out by power plants in other regions burning natural gas (or other fossil fuels).

With all these assumptions in the open, Northern Pass’s 5 million ton estimate is, in a word, indefensible. Northern Pass’s strategy of endlessly repeating this 5 million ton fabrication—to investors, to permitting agencies, and to the public— signals that Northern Pass version 2.0 will be pursued with exactly the same adversarial, greenwashing tactics that accompanied version 1.0. Worse, it reflects apparent contempt on the part of Northeast Utilities and PSNH for well-informed dialogue regarding a key supposed benefit of their project.

And we certainly need a rational, fact-based dialogue as the region embarks on what CLF hopes will be a productive and rigorous process for considering the merits of and best options for importing more large-scale hydropower from Canada. A clear-eyed regional approach requires real, well-grounded numbers addressing pollution and economic impacts. (The now-revived permitting process for Northern Pass needs them, too.)

Zombies need not apply.

Northern Pass’s “new route”

Today, we learned from PSNH President Gary Long about the Northern Pass transmission project’s long-awaited “new route.” As predicted, the “new route” hardly changes the original proposal and corrects none of its serious flaws. You can read CLF’s official statement on the announcement here.

It’s critical to see Mr. Long’s announcement for what it is: a desperate (one might say “last ditch”) effort to resuscitate his company, PSNH, and its failing business model of operating inefficient and costly power plants on the backs of New Hampshire households and small businesses, leading to the highest energy rates in the region. True to form, PSNH parent company Northeast Utilities and its shareholders would still collect the lucrative fees from Northern Pass partner Hydro-Québec, while PSNH customers, who have to live with the project, would likely see even higher rates if Northern Pass were built and PSNH’s power plants continue to operate (and pollute) as they do today. Nothing about today’s announcement changes that reality.

The “improvements” announced today involve moving a small portion of the project’s path through the northernmost towns in New Hampshire (a forty-mile stretch where an entirely new transmission corridor would be constructed) and include 8 miles of new underground lines, less than 5% of the overall route, to be buried in publicly-owned roads. Designed to make the project marginally less offensive to a few communities, these pathetically modest revisions are all PSNH can show for itself after two years and millions of dollars of closed-door land deals. Notably, Northern Pass does not currently have rights to use state and local roads and will seek them during the permitting process. In other words, Northern Pass could not find enough willing landowners to secure a complete route. Unaffected by the changes announced today, Northern Pass’s overhead lines would still cross the protected White Mountain National Forest, the Appalachian National Scenic Trail, the Pondicherry division of the Conte National Wildlife Refuge, and Bear Brook and Pawtuckaway State Parks, among other state lands and conservation areas.

Filled with gauzy statements about working with stakeholders and using precisely the same song and dance we’ve been hearing since 2010 regarding the project’s supposed benefits (complete with deliberate falsehoods about emissions reductions), Mr. Long’s announcement follows two years of adversarial, scorched earth tactics by PSNH, and PSNH affiliate Northern Pass Transmission LLC, like gaming the federal permitting process, attacking land conservation efforts, and blatantly misrepresenting the project’s support and its illusory economic and environmental benefits.

In this context, it’s not surprising that PSNH can’t keep its story straight. For example, Mr. Long is continuing to insist that Northern Pass needs no subsidies, even as the economic reality has changed and Northeast Utilities lobbyists have spent the last year fighting for subsidies to keep the project on track.

Likewise, the new plan to bury 8 miles of the project is flatly at odds with Northern Pass’s repeated insistence (including in a legal filing with the Department of Energy) that any burial would be too expensive. If burial is beneficial and practical for communities and stakeholders along a portion of the route, much more of the project – if not the whole line – should be sited underground, as Governor Hassan suggests in her first reaction to the route announcement.

Unfortunately, the new route moves the project no closer to a genuine solution that would bring meaningful economic and environmental benefits to New Hampshire and real progress toward a clean energy future for New England. It was just last week that CLF expressed cautious optimism that the region could benefit from imports of large hydropower from Canada, if the deals, policies and projects were done right. What is now clear: the “new and improved” Northern Pass project is nothing new, and isn’t the solution.

This past Friday, staff from the New Hampshire Public Utilities Commission and The Liberty Consulting Group issued the results of their investigation (PDF) into the impacts of PSNH’s failing business model and “ever higher costs” to consumers. The Union Leader and NHPR were quick to quote the report’s damning conclusion:

In summary, the situation looks to worsen, as continuing migration from PSNH’s default service by customers causes an upward rate trend. We find no supportable basis for optimism that future market conditions will reverse this unsustainable trend, especially in the near term. To the contrary, the PSNH fossil units face uncertainties that combine to create a risk of further, potentially substantial increases in costs.

This underlines the benefits of abandoning PSNH’s residential energy service, noting that “PSNH’s default service rate has exceeded [competitive supplier] rates since mid-2009.” As PSNH itself stated in a filing before the NH Supreme Court in May, PSNH energy service ratepayers “have the legal right and ability to avoid payment of PSNH’s default energy service rate entirely by buying their electricity from a competitive electric power supplier.” The PUC staff’s report serves as a call to action for New Hampshire consumers to save money, protect their finances, and improve the environment by buying energy from lower cost and more efficient energy suppliers.

PSNH’s only public response to the report thus far has been to cite the dispatch of their coal units during extreme temperature events this year as evidence that the plants are necessary “insurance” against natural gas price increases. The report itself contradicts this, however, noting that even at this year’s levels of natural gas price spike frequency and severity in New England (due to a cold winter and a late spring heat wave two weeks ago), natural gas price fluctuations “have not served to give the PSNH fossil units enough of a boost to overcome their negative value,” and that PSNH has not offered any data or analysis to rebut this finding. That is, even with the extreme peaks of electric demand felt in the past year requiring their use more often than in the past few years, PSNH’s fossil fuel fired power units still lose ratepayer money.

The report assesses the real financial impacts of PSNH’s past and possible future decisions to invest in their coal units rather than shut them down, and demonstrates that the ratepayer money lost if PSNH’s electricity generation is sold off will be lower than many might fear. The key points raised by the report include:

• Even in a best case scenario, PSNH’s already above-market rates will continue to climb. The investigation calculated PSNH’s energy service rates with a myriad of possible variables, including high natural gas prices and lower coal prices (the scenario that PSNH claims will validate its economic decisions) and a migration rate lower than PSNH reported this April. In all cases, the report found that PSNH’s default energy service rate would climb still higher than their current well above market 9.54 cents per kilowatt hour rate, to 10 or 11 cents per kilowatt hour.
• Customers continue to flee PSNH’s energy service. CLF has been reporting the steep increase in residential customers rejecting PSNH’s high energy service rates for a while now. We’ve also noted that most large commercial customers had migrated away from PSNH years ago. The combination of these two trends led to the report this May that migration across all customers reached half of PSNH’s total load as of the end of April.
• The full cost of the Scrubber Project has yet to be felt by ratepayers. PSNH has started recovering the cost of the ill-founded scrubber installation at Merrimack Station to the tune of 0.98 cents per kilowatt hour on a temporary basis. The report estimates that full recovery of the scrubber’s cost would nearly double that amount, to 1.8 cents per kilowatt hour added to ratepayers’ bills. This, of course, is a cost that competitive energy service providers don’t have to deal with.
• Looming environmental compliance projects as Scrubber redux? PSNH is currently waiting for its new final permit from EPA for cooling water withdrawal and discharge at Merrimack Station. The final permit is likely to require cooling water intake structures (like those constructed at Brayton Point Station in MA), at a price tag of $111 million or more, in addition to other protections for water quality and wildlife. Costs associated with new or impending air quality requirements would require additional compliance at significant cost, and these estimates don’t even take into account the risk posed by CLF’s ongoing Clean Air Act citizen suit.
• Potential ratepayer costs from divestment of PSNH’s electricity generation would be minimal. If PSNH’s generating assets are sold, New Hampshire state law allows PSNH to recover from ratepayers costs that are not covered by sale proceeds (“stranded costs”). The report roughly estimates that potential energy service rate increases to cover stranded costs would be no more than 0.9 cents per kilowatt hour and possibly much less, given the high value of PSNH’s hydro generation units.

The report ultimately recommends that the PUC initiate a proceeding to solicit formal feedback on the report and its conclusions. This proceeding would likely result in firmer value estimates for PSNH’s assets, interim steps that could be accomplished through the PUC’s existing authority, and more detailed recommendations for legislation.

As CLF and the Empower NH coalition have repeatedly noted, promoting and advancing competition in New Hampshire’s energy service markets yields only benefits for the state’s electricity ratepayers in the face of PSNH’s “ever higher costs” to ratepayers. While the PUC and the Legislature decide how to implement the recommendations of this report, ratepayers should continue to vote with their feet and leave PSNH’s energy service.

(photo credit: flickr/crschmidt)

With the Northern Pass “new route” drama entering its third year (Northeast Utilities executives once again failed to announce any progress on last week’s investor conference call), it’s important to remember that all we’ve been talking about is the northernmost forty miles of what is a 180-mile project that stretches from the Canadian border to southeastern New Hampshire.

The “new route” will not change one of the proposed Northern Pass project’s most troubling segments: approximately 10 miles through the White Mountain National Forest, within the towns of Easton, Lincoln, and Woodstock. It goes without saying that the Forest is one of New Hampshire’s most treasured public assets: a vast and magnificent wilderness that is among the most accessible and visited natural wonders in the nation and the cornerstone of the state’s tourist and recreation economy. The Forest is an awe-inspiring place, and its ongoing stewardship is one of those things that make me profoundly proud of this country.

Project affiliate Public Service Company of New Hampshire (PSNH) has a “special use permit” from the United States Forest Service for an existing transmission line, built in 1948, which is largely comprised of H-frame wooden poles standing about 50 feet tall. Northern Pass developer Northern Pass Transmission LLC (NPT) is now seeking a special use permit to remove the existing line and build two new sets of towers (one carrying the new Northern Pass transmission line and the other carrying the existing line) with a “typical” height of 85 feet.

Proposed Northern Pass tower design (existing towers in background)

You can read NPT’s permit application here (PDF) and download its attachments here. The project’s construction would impact important wildlife habitat and ecologically sensitive high-altitude wetlands, and the new more prominent towers would cross the Appalachian Trail and impact a number of the Forest’s other signature hiking areas and viewsheds. It’s also worth noting that the project’s failure to provide meaningful greenhouse gas emission reductions falls particularly hard on the Forest, where climate change is already shifting seasons, reducing snowpack levels, and disrupting mountain ecosystems in significant ways.

It will be up to the United States Forest Service – and specifically the supervisor of the White Mountain National Forest  – to decide whether to approve NPT’s permit application. In particular, the Forest Service must determine whether granting the proposed use is “in the public interest” and consistent with the current management plan for the Forest, which includes special protections for the Forest’s most important natural and scenic resources. This decision will follow the United States Department of Energy’s environmental review of the Northern Pass project as a whole, which CLF has been fighting to improve since the project was first announced in 2010.

Earlier this year, a diverse coalition of conservation organizations, including CLF, along with a grassroots group, several Forest communities, and the regional land use planning commission wrote to the Forest Service, urging the agency to take all available steps at its disposal to ensure comprehensive and rigorous scrutiny of the Northern Pass project and a full analysis of all reasonable alternatives, especially those alternatives that avoid or minimize impacts within the Forest.

Our letter (PDF) highlighted the Forest Service’s stewardship obligations and the special and stringent standards for granting a special use permit. We explained that the Northern Pass project, as proposed, is very different from an ordinary utility transmission line constructed to extend service or improve system reliability; the project is much more like a private commercial development, with no specific policy or law encouraging or requiring its development. We suggested that it was critical for the Forest Service to take these features into account as it weighs whether the project would be consistent with the “public interest” and the Forest’s management plan. Finally, we recommended that the Forest Service avoid relying on data collected by the first contractor hired to conduct the federal environmental review of the project, which was withdrawn by NPT after a public uproar, and that the Forest Service exercise its prerogative to order Forest-specific studies and to scrutinize and question all data and analysis presented by the current contractor team, the objectivity of which is in serious doubt.

Oddly, the federal environmental review of Northern Pass seems to be moving forward even as the project is stalled and the northernmost route has not been disclosed. As field work, studies, and analysis proceed, the Forest Service is hearing from many voices registering strong opposition to Northern Pass’s special use permit application, through efforts like ProtectWMNF.org and this recent citizen-generated petition. If you are concerned about the impacts of the Northern Pass project on the White Mountains, you can add your voice through those resources or by filing a comment with the United States Department of Energy.

Source: HAM Guy, Flickr.
New Hampshire’s state flower, and my favorite sign of spring.

It’s another spring in New Hampshire, and the slow death of Public Service Company of New Hampshire’s (PSNH) coal-fired business model continues, as do PSNH’s efforts to hold back reality and hold on to its regulatory protection from competition. More and more PSNH customers are choosing cleaner, cheaper energy options, the company is again getting special treatment as it initiates a strange new program to lure those fleeing customers back, and its dirty and inefficient coal plants are once again sitting idle, with PSNH customers still paying for their upkeep.

Increasing Choices for PSNH Customers

PSNH (and shareholders of PSNH’s parent company, Northeast Utilities) must be wondering when the rate of residential customers abandoning PSNH’s energy service will slow. It certainly wasn’t during the first three months of 2013, when the number of households purchasing power from PSNH’s competitors topped 49,000. By comparison, that number was 2,704 at the end of March 2012.

The number of small businesses migrating away from PSNH has steadily increased, from 11,194 in March 2012 to 16,919 this March. Of course, PSNH’s medium and large commercial customers have been taking advantage of competitive suppliers since long before it was a practical option for residents, and they move back and forth from PSNH and the competitors much more frequently; in any given month, between 75% and 90%+ of medium and large businesses purchase their power from PSNH’s competitors.

Source: PSNH data

We last checked in on PSNH’s accelerating death spiral in January, highlighting the historically low use of its coal plants to produce power and the flight of customers away from PSNH’s ballooning rates. The utility’s ancient, filthy coal plants are sitting idle for large stretches of time during the year, at substantial cost to ratepayers, because PSNH is able to recover its costs and a guaranteed profit from its customers even when it isn’t economic to put the plants online. Despite a winter when the spot market price of natural gas was very volatile, PSNH’s coal plants provided no economic relief to its customers, as its energy rates remained almost 40% higher than those offered by other New Hampshire utilities and energy suppliers.

In response to the huge disadvantage posed by PSNH’s coal plants, the competitive atmosphere has continued to flourish in New Hampshire’s energy market in 2013. We’ve previously highlighted the residential energy services offered by companies like ENH Power and North American Power, and still more companies are hurrying to take advantage of PSNH’s above-market rates by siphoning off customers.  As the Union Leader recently reported, four new competitive suppliers have applied for licensing with the NH Public Utilities Commission already this year.

The “Alternative Default Rate”

Looking to secure a special deal to protect itself from its new competitors, PSNH applied for and received [PDF] regulator approval to pilot an “alternative default rate” to lure back customers who had switched to other suppliers. The alternative rate will only be available to large commercial customers at first, with small businesses and residential customers to be added to the program within nine months.

After the increased public awareness of competitive electricity supply in NH around the end of 2012 rate hike, the press and public were quick to take note of this plan, and customers who stayed with PSNH through the January rate hike feel doubly burned.

Saving by Switching

After PSNH’s astronomical rate hike in January, the energy rates offered competitive suppliers like ENH Power and North American Power should be even more attractive to PSNH customers who were previously cautious about making the switch. And switching online is easy, free, and safe: it takes a matter of minutes if you have a copy of your latest PSNH bill handy.

As spring turns to summer, and PSNH’s troubles grow, the ongoing challenge remains: to ensure that clean energy competition continues to flourish in the Granite State and that PSNH does not secure a legislative or regulatory bailout that subsidizes its dying business model. Although PSNH doesn’t seem willing to change its terrible economic decision to keep operating its coal plants, New Hampshire residents and businesses are taking matters into their own hands and deciding to do something about it.