Merrimack Station power plant in Bow, NH. (Photo credit: John Moses)

Today CLF filed a federal Clean Air Act citizen suit in New Hampshire federal district court against Public Service Company of New Hampshire (PSNH), the owner of Merrimack Station power plant for the plant’s repeated failures to obtain required air permits. CLF’s citizen suit also cites numerous violations of Merrimack Station’s current permits and the resulting illegal emissions from the plant.

Merrimack Station  is among the most polluting coal-fired power plants in New England and is the single largest source of greenhouse gas emissions in New Hampshire, releasing over 2 million pounds of toxic chemicals every year. In addition, the plant is causing PSNH’s energy rates (already the highest in New Hampshire) to steadily climb as ratepayers are forced to foot the bill for the above-market cost of keeping PSNH’s old coal plants in operation.

CLF’s complaint contends that the plant, which is more than a half-century old and is in the midst of a major, multi-faceted life extension project, never obtained required permits authorizing renovations to major components of Merrimack Station, including much of an electric-generating turbine, even though the changes increased pollution from the plant.  As predicted by PSNH’s own projections, the changes led to more emissions of pollutants, including smog-causing nitrogen oxide and particulate matter, or soot, which causes respiratory problems when inhaled and is linked to increased hospitalizations, lung damage in infants and children, and premature death.

“In the course of this project, PSNH has repeatedly violated the Clean Air Act, putting the health of the public, especially children and senior citizens, at risk,” said Christophe Courchesne, CLF staff attorney. “PSNH is not above the law and CLF is committed to holding them accountable. With PSNH trumpeting the supposed ‘clean air’ benefits of the Northern Pass project with full-page ads in newspapers across New Hampshire, it is imperative to shine a light on PSNH’s coal plants, which easily cancel out the purported benefits of Northern Pass.” Read more >

PSNH's Merrimack Station (photo credit: flickr/Jim Richmond)

I appeared on NHPR’s The Exchange with Laura Knoy this morning, and the topic was the potential energy and economic impacts of the Northern Pass project. The show provided a good opportunity to explain why the project is inspiring so much opposition, why CLF has been skeptical of the current proposal, and how Canadian hydropower could play a role in the New England electric system if pursued appropriately. There was also a segment on the project’s potential impact on property values. You can catch the replay here if you’re interested.

Joining me on the show was Julia Frayer, an economist hired by the Public Service Company of New Hampshire (PSNH) to tout the energy and economic benefits of the project. Recently, she penned a widely-reprinted op-ed and provided testimony to the New Hampshire legislature, suggesting the project will be a boon to consumers and the reliability of the electric system.

Unfortunately, and as I made an effort to point out on the show, the arguments for the current proposal are pleasant talking points without much to back them up. All the cited benefits are speculative, rather than firm commitments, and are not forthrightly presented alongside the proposal’s potential costs. As any student of economics can attest, an intelligent discussion about the economics of a project requires that we at least try to describe and compare the costs and benefits.  We know that the project may have significant negative impacts, ranging from the environmental impacts of generating the power in Canada to the potential effects of major new transmission lines on New Hampshire’s tourism and recreation industries. PSNH and the project developer, Northern Pass Transmission, LLC, have stubbornly failed to acknowledge these impacts, and there is no evidence they were taken seriously in the planning of the current proposal.

One point worth highlighting – the current plan calls for all of the supposed clean energy benefits and electric rate reductions to be delivered through the wholesale market, where Hydro-Quebec intends to sell the power delivered by the project.  But these benefits would mostly bypass the very residential ratepayers in New Hampshire who pay PSNH for electricity – because PSNH acquires very little power from the wholesale market. Instead, as customers of PSNH’s retail power, PSNH residential customers have been left to shoulder the uneconomic costs of PSNH operating several coal-fired generating units – and to pay the highest electric rates in New Hampshire as a result. Northern Pass does nothing to change this situation.  Many commercial ratepayers in PSNH territory have “migrated” in increasing numbers to other utilities that – unlike PSNH – do buy substantial power from the wholesale market to supply their customers. Residential ratepayers don’t have this choice – which means they’re saddled with PSNH’s higher costs, as PSNH loses more and more of its commercial rate base.  Again, Northern Pass does nothing to change this situation.  On closer inspection, the claimed benefits for New Hampshire consumers look more like phantom benefits than anything real.

The proposal promises to send huge profits to Hydro-Quebec, as it bids power into the wholesale market (easily paying back its investment in the transmission lines), and to provide a revenue stream of transmission payments to Northeast Utilities, PSNH’s parent company. But this structure makes very little sense because it means New Hampshire residents will continue to bear the burden of high cost power and dirty air from PSNH’s coal plants and will also face the environmental and economic impacts of a massive transmission project, while the power would only displace relatively less-polluting natural gas generation and may undermine the development of local renewable energy projects in the state. If it does indeed lower costs on the New England market, the effect will be to increase costs for PSNH’s residential customers as more large customers migrate to the competitive market and fewer customers are left to pay the costs of PSNH’s expensive coal plants.

The current proposal is coming into focus as a bad energy and economic deal for New Hampshire, and regionally the benefits seem less than impressive – especially because the emissions reductions made possible could be so much greater if there was a firm commitment to pair the new imports with the retirement of coal-fired units. As the project continues to wind its way through the federal and state permitting process, CLF will keep pushing for the project to make sense for New Hampshire and for the energy future of the region as a whole.

For more information about Northern Pass, 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.

Photo credit: Marilyn Humphries

For those of you looking for a good clean-energy read, check out this recent article by Climate Progress’s Stephen Lacey. Lacey focuses on the common myth that clean energy and climate reduction policies will mean higher energy costs for consumers, pointing out that two recently released reports show that the implementation of cleaner, more efficient energy systems will actually save them money in the long run. The same myth has been perpetuated regarding the Regional Greenhouse Gas Initiative (RGGI) here in the Northeast. To debunk that notion, Lacey quotes CLF’s VP for Climate Advocacy and Policy Seth Kaplan:

“The fact is, RGGI is a very, very, very small piece of the overall cost of electricity. There are so many costs that are much greater. Pulling out the cost of RGGI would be like factoring in the cost of mowing the lawn at the power plant or factoring in the property taxes. Some of the claims that groups are making about the cost of the program are patently absurd.”

To hear more from Seth on the subject, read the full article here.

Articles in this morning’s Boston Globe and Salem News describe an important shift in the status of Salem Harbor Station and highlight the need for ISO New England (ISO-NE) to go beyond the analyses it has done in the past so that it can finally identify an alternative that will actually solve the reliability issue that has dogged efforts to retire the plant since 2003.  That is the subject of the recent protest filed by CLF asking the Federal Energy Regulatory Commission to require ISO-NE to perform an expedited analysis of the alternatives and establish a timeline for implementation.

ISO-NE’s failure to identify solutions that will relieve the need for Salem Harbor Station has resulted in decisions that will cost ratepayers up to $18.5 million in above market payments in 2012-2013 and up to $16.9 million in 2013-2014. ISO-NE could avoid imposing these costs on ratepayers by implementing an alternative that would allow the plant to retire by 2012.

However, if ISO-NE rejects Dominion’s recent “permanent delist bid” – its latest and most telling signal that it wants to retire the plant – on the basis of reliability, ratepayers face the risk of even higher costs. The reality is that ratepayers pay more per kilowatt for electricity from Salem Harbor Station than they pay for other sources of electricity in the capacity market ranging from natural gas to nuclear and renewable.  This dispels the perception that coal is a cheap source of electricity.   Importantly, these additional costs aren’t spread among ratepayers throughout New England; instead, they are passed on solely to the ratepayers in northeastern Massachusetts, the same people who already bear the costs of additional medical expenses from the heart and lung diseases and other illnesses caused by pollution from the plant.  A study released by Clean Air Task Force concluded that pollution from the Salem Harbor Station causes 20 deaths, 36 heart attacks and 316 asthma attacks every year.

These costs diminish any economic benefits that the City of Salem receives from tax payments and jobs at the plant, and the likelihood that Dominion will retire in 2014 if its de-list bid is accepted makes it more important than ever that an alternative use for the site be developed to replace the facility.

Dominion’s claims that it is not planning to retire the plant contradict its own filings before the Federal Energy Regulatory Commission.  Continuing a tradition of telling the story that best suits its interests depending on the audience, Dominion told the Commission in a 2009 filing that it estimated only three more years of economic viability for the plant.  Dominion spokesman Dan Genest told the Salem News, “We know what it costs us to produce a megawatt of electricity at Salem Harbor Station, and the lower price at auction is not enough to cover our costs to generate electricity.” Despite its claims that it can continue to make profits in other markets, Dominion has said in its own filings that it was likely to lose money in those markets.

The bottom line is that ISO-NE has a responsibility to find an alternative to replace Salem Harbor Station that will cost less.  Now that the threat of even higher costs looms, protecting ratepayers demands a solution by no later than 2014, and the public health and environmental harms caused by the operation of this 60 year old coal and oil-fired relic weighs heavily in favor of shutting down the plant as soon as possible.