Four Important Footnotes to Northern Pass’s Latest “Approval”

Christophe Courchesne

With its public relations machine in triumph mode, the developer of Northern Pass announced on New Year’s Eve that the project had received the approval of ISO-NE, the operator of the regional electric grid, attaining what the developer called a “major regulatory milestone.” The Associated Press picked up the press release, as did local outlets that repeated the developer’s phrase without much context over the New Year’s holiday. But four key aspects of Northern Pass’s “approval” didn’t get much notice:

  • The ISO-NE action was limited to a decision regarding whether and how Northern Pass could connect to the grid without major problems elsewhere.

Indeed, the approval is a very early step for every energy project in New England; the Cape Wind project earned its approval in 2005, and ISO-NE issues dozens every year. In this case, it took three years of apparently intense studies and engineering work for ISO-NE to reach the conclusion that plugging in Northern Pass by itself would in fact cause meaningful problems but that those problems could be adequately managed with further, mostly unspecified upgrades elsewhere in the transmission system. In the words of ISO-NE’s letter, it “is limited to a review of the reliability impacts of a proposed project as submitted by Participants and does not constitute an approval of a proposed project under any other provisions of the ISO Tariff.” Neither ISO-NE nor anyone else has determined that the project would improve or is needed for electric system reliability

  • Major questions remain about what additional upgrades are needed to accommodate Northern Pass while ensuring system reliability, and what those upgrades will cost.

ISO-NE’s approval specifies a number of extremely substantial and costly upgrades at substations south of the project’s terminus in Deerfield, NH. The costs of these upgrades, who will pay for them, and whether they are included in the $1.4 billion project cost are unclear. Also uncertain is the cost of changes that other power plants may need to make to ensure system reliability. Indeed, the ISO-NE approval letter punts many vital issues to further study when the project’s engineering plans are more advanced. In other words, ISO-NE’s decision is far less definitive than Northern Pass PR would suggest.

  • ISO-NE’s decision was controversial and hard-fought, which is virtually unheard-of for this type of approval.
Map from Northern Pass I.3.9 presentation to NEPOOL Reliability Committee

Map from Northern Pass I.3.9 presentation to NEPOOL Reliability Committee

For most projects, this approval (known as an “I.3.9” for the provision of ISO-NE’s tariff that requires it) is pro forma and readily granted, with the endorsement of the Reliability Committee of the New England Power Pool, a group of utilities, energy companies, and government and “end user” stakeholders with interests in the electric system. This time, and despite three years of consultations between Northern Pass’s developer and ISO-NE to study the project’s impacts and to craft conditions for the approval, the Reliability Committee failed to endorse the Northern Pass I.3.9 applications. As discussed in a subsequent article in the Union LeaderNorthern Pass’s developer chalked this up, with a distinct lack of professionalism, to New England-based power plants’ fear of competition from Northern Pass. To the contrary, as the article points out, a variety of stakeholders from multiple sectors objected because the information provided by Northern Pass and ISO-NE did not resolve important technical questions about how the project would affect the regional power grid, including the power plants we are currently using to keep the lights on. ISO-NE’s decision to overrule the Reliability Committee has raised concerns about the fairness of its process to stakeholders, the influence of Northeast Utilities (New England’s largest utility and an owner of a major part of the region’s transmission system) with ISO-NE officials, and the underlying technical merits of the approval.

The ISO-NE approval and associated studies will no doubt play a role in the agency’s review, but the decision is not necessarily limited to the issues that were before ISO-NE and—unlike ISO-NE’s process—the public will have an opportunity to provide comment before the agency makes its final decision.

Far from demonstrating the project’s progress, the ISO-NE action and its context are the latest evidence that Northern Pass’s developer is pursuing its preferred proposal with a single-minded refusal to consider alternatives that would deviate from the project’s current configuration and route. There could be—and CLF is confident there is—a better way. If the region took a holistic view of transmission (and non-transmission) options, some of those options could involve fewer technical challenges and upgrade costs than Northern Pass’s proposal to deliver 1,200 megawatts to Deerfield, New Hampshire, in close proximity to numerous other large power plants. CLF will keep fighting to ensure those options are fully considered as the permitting process for Northern Pass continues.

Learn more about Northern Pass here or by signing up for CLF’s email newsletter, Northern Pass Wire. For the latest Northern Pass updates,  follow me on Twitter.

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3 Responses to “Four Important Footnotes to Northern Pass’s Latest “Approval””

  1. Mark Orzeck

    The approval also mentioned that NP needs to come up with a way to safegard against a single event taking out both the Phase 2 HVDC and NP lines at the border crossing. They suggested “undergrounding” in that area….

  2. Leo C Stevens Jr

    When I worked for Mass. DOT, the EIS for highway projects needed to have consideration of a no-build option, does the EIS being prepared for Northern Pass have such a requirement?

    • Christophe Courchesne

      Leo – Yes, DOE must consider a no-build option as part of the EIS. It has committed to do so in its statements in the Federal Register. The question now is how robust the analysis of that alternative will be.

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