CLF and Allies to Department of Energy: Take off the Blinders in Northern Pass Review

Christophe Courchesne

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.

Focus Areas

Climate Change


New Hampshire


Northern Pass

6 Responses to “CLF and Allies to Department of Energy: Take off the Blinders in Northern Pass Review”

  1. Roger Dennison

    To ward off catastrophic climate change, the world must transition from fossil fuels to alternatives as quickly as possible. Those who care about the planet on which they live should make it their first priority to see that nothing prevents the rapid introduction of large-scale, cost-effective low-carbon energy. CLF should support the use of public funds to lower the cost of alternative energy. It should support power lines to bring low-carbon energy into the region, and recognize that delay carries a grave cost.

    • Christophe Courchesne

      Thank you for your comment. CLF wholeheartedly agrees with the need to do everything we can to combat climate change–it is at the core of our advocacy everyday. Unfortunately, many of the conclusions at the core of your comment — that transmission projects to import Canadian hydropower are necessarily cost-effective and low carbon — are not self-evident. CLF has continually emphasized that there are potential ways to get new hydropower imports right, but not through projects that fail to respect host communities, to provide meaningful climate benefits, or to complement — rather than displace — other cleaner options based in New England like wind, solar, and energy efficiency.

  2. Roger Dennison

    In order for New England to do its share in averting catastrophic climate change, it will need to transition essentially all of its electricity generation to non-carbon sources within the next 30 years, and the electriciyty requirements will increase as electricity is substituted for fossil fuels in industry, space heating and transportation. Excellent background on this is provided by the recent UN report on deep decarbonization (, see DDPP). It is inconceivable that sufficient wind and solar power can be implemented within densely populated areas to support this transition. New power lines will be essential to move electricity from remote areas to populated areas. Will CLF be willing and able to push back against local opposition to see that needed power lines are built when and where they are needed?

  3. John Lawrence

    I applaud the efforts of CLF in their support of a comprehensive, transparent and regional approach to sorting out this regional/cultural challenge.

    It should be clear that the NP proponents are quite interested in leveraging some of their existing assets to boost profits. Business is business, and that is their right.

    As both consumers of energy and stewards of this wonderful living space, we owe it to ourselves to carefully plan and execute on these major initiatives for the maximum benefits to the most people, and the minimal detriment of all involved. From my vantage point, CLF is filling the void nicely to push the development process squarely in such a direction.

    There are considerable existing rights of way that may be utilized to minimize environmental and community detriment. The business model for the NP does not want to veer into the alternatives as this would seriously limit it’s revenue projections. Business is business.

    Like so many other business models, it is the “externalties” that prop up the profit because the is no free-market inclusion for societized costs like environmental or aesthetic degradation.

    Carefully planned, capitalist activities can marry sustainability with profit, but it requires an adjustment of thinking within a much bigger box. I believe that CLF is showing all of the players how large the box might be, and inviting all willing parties to develop the best long-term solutions for the widest population possible. Anything worth doing is worth doing right.

    Keep up the positive work.

  4. miriam kurland

    I just cannot understand how we continue to be barraged by proposals that coerce us into falsely believing that we need these large scale, costly and harmful power lines. We need to move towards conservation of power along with interconnection of small, local, municipally owned renewable power sources that are responsive to environmental and social needs of our communities. I am tired of the powers that be spreading propaganda about the need for these power lines, even while the public is smart enough now to resist this nonsense.

  5. Searle Redfield

    Mr. Dennison…. Please answer the following question honestly.
    Without exact specifics, where do YOU live? Do you live or otherwise have a vested interest in New Hampshire’s economy, tourism industry or general environmental well-being? And remember, please be transparent.
    I can’t imagine anyone who actually lives north of, say, Tilton would seriously want this when less impactful alternatives are available to supply ” lower New England”.

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