Small Step on a Long Hike: DOE Plans to Consider a Long List of Northern Pass Alternatives

Christophe Courchesne

Yesterday, the U.S. Department of Energy (DOE) published an update on the Northern Pass project permitting process, offering the first signals of which alternatives to the developer’s proposal DOE will evaluate during its environmental review process.

Posted to DOE’s website, the report is compellingly titled a “scoping report alternatives addendum” and provides a list of the 24 alternatives DOE has identified to date “for analysis” in its draft Environmental Impact Statement, or “EIS.” DOE compiled the list from information provided by the developer, DOE’s own work, the many public scoping comments on alternatives, and input from other government agencies. They range from the “no action” or no-build alternative to underground transmission lines to non-transmission alternatives like further energy generation and conservation within New England. (The report is an addendum to DOE’s unremarkable report, published in March, that briefly summarizes the EIS scoping process that ended last November as well as the thousands of public comments on the project.)

The report is an important but modest step towards transparency in an embattled three-year permitting process that has been all too susceptible to the perception that it is proceeding myopically and under the inappropriate and excessive influence of the project developer, Massachusetts- and Connecticut-based Northeast Utilities. It took a three year effort by CLF and our advocacy partners, as well as the extraordinary, sustained commitment of the entire New Hampshire Congressional delegation, speaking with one voice on three occasions, to win DOE’s agreement to publish the report.

Long-List-of-Northern-Pass-Alternatives

A DOE-identified underground alternative to Northern Pass along state roads through the White Mountain National Forest

As much as the fact of the new alternatives report is a step forward, the report itself is something of a disappointment. Although there are a few silver linings, the report fails to answer a number of key questions about the direction of DOE’s review of Northern Pass.

Our observations:

  • DOE stops short of defining which alternatives on the list are “reasonable alternatives” that will be studied in detail in the EIS. This is the key information that the public should know before DOE commits its resources to preparing a massive report on those alternatives. Indeed, defining what alternatives are “reasonable” is the decision that will determine whether DOE is undertaking a truly comprehensive analysis or is following the overly narrow approach that Northeast Utilities would prefer. All we have now is a list, with no indication of how the list will be narrowed down as DOE prepares the EIS. An aside: if DOE has not yet made these decisions, it clearly has a very long way to go before it publishes a complete draft EIS, and it is hard to see how DOE will meet its end-of-2014 target for releasing the document.
  • DOE lacks a set of clear, guiding principles for selecting which alternatives should be studied. To identify alternatives to a project, it is important to know the “purpose and need” for the project that alternatives should fulfill. In this case, DOE continues to say, in circular fashion, that the “purpose and need” for its review of Northern Pass is to consider whether to grant a permit to Northern Pass. As CLF and our advocacy partners have pointed out on numerous occasions, this is an illegally narrow definition that does not provide a helpful framework for identifying an appropriately broad set of alternatives.
  • DOE is too focused on identifying routes and configurations for transmission lines beginning in Pittsburg, New Hampshire, and ending in Deerfield, New Hampshire, reflecting Northeast Utilities’ preference. There are numerous other potential border crossings and terminal stations for a new transmission line (including New Hampshire substations and power plants owned by Northeast Utilities’ subsidiary PSNH but also in other states). Although the report describes a number of important alternatives that do not involve power lines between these two points, the report’s descriptions of many of those alternatives are much more cursory and vague, raising the concern that the DOE will not study them with adequate detail or seriousness.
  • The most encouraging aspect of the report is that DOE seems to have made a serious effort to identify and map underground alternatives to Northern Pass. About half of the alternatives listed include some underground component, and several involve complete burial of transmission lines. The report defines potential underground routes and describes key technical imperatives—such as a relocated converter station—for an underground project. As I’ve argued, underground alternatives are cost-competitive with overhead transmission lines and must be rigorously evaluated in the EIS. To the extent the report signals that several underground transmission configurations and routes will be studied in detail in the EIS (over Northern Pass’s strenuous objection), it’s good news and exactly what the New Hampshire environmental community and many others in New Hampshire have been seeking.
  • Northeast Utilities’ praise of the report rings hollow. In a statement on its project blog and on this morning’s quarterly investor call, Northeast Utilities welcomed the report. It’s an odd stance given that Northeast Utilities opposed the environmental community’s request for the report until days before DOE agreed to prepare it, and its amended permit application filed last year reads more like a legal brief against robust consideration of any alternatives (save one potential—and illegal—route through the Connecticut Lakes Headwaters conservation easement area in far northern New Hampshire). Moreover, trumpeting a report that highlights the many strong alternatives to the current proposal as some kind of evidence that the process is moving toward near-term approval of the project marks an unfortunate continuation of the project’s utterly disingenuous (and apparently ineffective) public relations campaign.

As CLF has argued for three years, DOE’s choice of which alternatives to study is crucial. Elected officials and the public have repeatedly voiced strong interest in alternatives to the current proposal, and a comprehensive and rigorous alternatives analysis is fundamental to reaching well-informed decisions on the project’s permit applications. Indeed, an objective and thorough analysis of alternatives is commonly considered “the heart” of the National Environmental Policy Act—the law DOE is required to implement as part of its permitting process. Despite encouraging signs in DOE’s alternatives report, it remains to be seen whether DOE will do the detailed study of Northern Pass alternatives that federal law requires and New Hampshire deserves.

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