Back in May, the U.S. Department of Energy (DOE) issued a report listing the alternatives to the Northern Pass transmission project that the agency may study during its environmental review. As I explained at the time, the report was a hard-won victory for transparency in the federal permitting process for Northern Pass. Unfortunately, the report failed to answer key questions, to include obvious and reasonable alternatives, or to demonstrate that the agency was independently and impartially considering the public’s feedback.
Last week, CLF and several environmental allies explained the problems with the alternatives report in detailed comments to DOE and the other federal and state agencies participating in the environmental review (PDF here, 6MB .zip archive of exhibits here). Our message: DOE must consider a broader set of alternatives to the project than those listed in the report and take additional steps to ensure a fair, open, and thorough process. We make these specific points:
- Despite enumerating underground alternatives that would make use of Interstate 93, DOE inexplicably ignored alternative configurations that would make use of the Interstate 91 corridor and the Derby Line border crossing. Likewise, DOE failed to list many project routes that would be possible if the project’s Deerfield, New Hampshire terminal station were relocated to another substation elsewhere in central or southern New England.
- DOE fails to list the obvious alternative of making full use of existing transmission lines that originate in Québec. As CLF highlighted last year, those lines are rarely full to capacity, and modest transmission equipment upgrades in neighboring New York could allow for much greater power flows.
- DOE improperly continues to list an alternative route, included in Northern Pass’s developer’s amended permit application, that would illegally cross the Connecticut Lakes Headwaters Easement in northern New Hampshire, in violation of federal and state land conservation commitments.
- There are troubling indications in the alternatives report that Northern Pass’s developer continues to have a major influence on the direction and scope of DOE’s environmental review through private communications with DOE that have not been disclosed. This needs to stop, and we propose a number of steps that DOE should take to make the process more transparent, such as announcing the alternatives DOE intends to study in detail prior to release of its draft environmental impact statement, adding to its website all information provided to the agency or its consultants by Northern Pass’s developer, and convening a stakeholder committee with public meetings to receive regular updates on the process and advise DOE on its work.
But our most important request is one that several of our groups have made before: DOE should take a regional view and evaluate all pending north-south transmission proposals together in one comprehensive environmental and economic study. While our motion for such a study in 2011 highlighted the still pending Champlain Hudson Power Express project in New York and Hydro-Québec’s ambitious export plans, a flood of new transmission proposals to import Canadian hydropower have emerged since then. Most recently, Northern Pass’s own sponsors—Hydro-Québec and Northeast Utilities—have themselves submitted interconnection requests for additional international transmission projects between Québec and Vermont. While DOE’s alternatives report does briefly mention several earlier projects as potential Northern Pass alternatives, its list is incomplete, and it’s not clear from the report that DOE intends to study them in detail.
Under federal law, DOE is charged with taking a “hard look” at the environmental and economic impacts of these projects and determining whether they are “consistent with the public interest.” If DOE is to meet its obligations, conducting silo-ed permitting processes for each project without taking a broader view first makes very little sense. As the New England governors are pursuing a rushed regional deal to fund new transmission projects with apparent disregard for comprehensive and rigorous environmental and economic analysis, it is essential that DOE and the other agencies involved carefully review Northern Pass in the context of all the other proposals vying to bring Canadian hydropower south and their alternatives, including local renewables and energy efficiency.
It is not too late for the federal environmental review of Northern Pass to take off its blinders and change course. Please join CLF and our allies—the Appalachian Mountain Club, the Nature Conservancy, and the Society for the Protection of New Hampshire Forests—in calling on DOE to consider a broader range of alternatives to Northern Pass in a comprehensive environmental impact statement on the full list of transmission projects that New England is considering. You can submit a comment on DOE’s website here.