Last night, CLF filed detailed written comments with the U.S. Department of Energy (DOE) regarding the scope of the Environmental Impact Statement (EIS) for the Northern Pass project. (A PDF of our comments is here.) First and foremost, our comments urge DOE to stay the Northern Pass proceeding and instead conduct a comprehensive, regional analysis (a comprehensive EIS) of the region’s need for Canadian imports, to enable sound planning as opposed to the piecemeal, project-by-project approach DOE is currently taking by simply reacting to the permit applications of private entities like Northern Pass.
Our comments expand on the remarks (PDF) I made at the Pembroke scoping meeting last month and come on the heels of yesterday’s major news that (1) Northern Pass wants DOE not to consider some alternative routes it included in its Presidential Permit application and also needs more time to discuss additional potential routes through the North Country (a PDF of Northern Pass’s filing is here and coverage on NHPR here) and (2) DOE is reopening the scoping public comment period through a date to be determined in June. The fact that Northern Pass itself has asked for a delay to reconsider aspects of its project is an even stronger indication that DOE can and should take the time it needs to undertake a full regional analysis through an open, and collaborative public process.
Our scoping comments note that the Northern Pass project is just one piece of a generational strategy on the part of Hydro-Québec and the Province of Québec to exploit the abundant natural resources in Québec’s northern tier with new hydroelectric generation projects and to step up exports to the United States. New England states have also expressed interest in accessing low-cost renewable power under the right conditions.
Given federal law’s requirement that DOE consider the cumulative impacts of the project, and DOE’s unique technical competence on energy planning issues, CLF believes that we need an open regional conversation on energy needs, the environmental impacts of Canadian hydropower, the best available transmission technologies, and the alternatives to imports, including renewable energy sources and non-generation strategies like energy efficiency and conservation. We think that the time for this conversation is now. Reviewing each project that crosses the border in a piecemeal fashion is simply the wrong approach to an issue of such regionwide importance. New England already has substantial import capabilities through existing interconnections; DOE is currently reviewing two separate applications to bring power into the northeastern United States – the Champlain Hudson Power Express and Northern Pass; and we expect there will be more proposals in the future to expand existing interconnections or build new ones.
And, consistent with our prior comments and those of Senator Ayotte and Congressman Bass last Friday, our comments also call for DOE’s EIS to consider and compare all reasonable alternatives to the project proposal – including siting, design, and non-generation alternatives. We also emphasize that the EIS must include a searching, technically detailed account of all environmental, social, cultural, and economic impacts associated with the project, as federal law requires.
We hope our filing will be a helpful resource for those preparing their own comments during the reopened public scoping comment period. In the meantime, we will be keeping the pressure on DOE to act on our request for a post-scoping, pre-draft-EIS report announcing DOE’s intended plan for drafting the EIS and our recommendation that DOE step back and begin the process of preparing a comprehensive EIS.