tag:blogger.com,1999:blog-44026311600358304222024-02-19T22:44:03.698-08:00Bury the Northern PassUnknownnoreply@blogger.comBlogger224125tag:blogger.com,1999:blog-4402631160035830422.post-4135281062720977932023-03-09T17:00:00.024-08:002023-03-09T18:24:57.824-08:00<p><i> <span style="font-size: 11pt; white-space: pre-wrap;">HB 609, a bill to abolish the Site Evaluation Committee and transfer its role to the NH Public Utilities Committee. Public and state agency members on the current SEC would be removed.</span></i></p><p><span style="font-size: 11pt; white-space: pre-wrap;"><i>March 7, 2023 Hearing</i></span></p><span id="docs-internal-guid-816016bf-7fff-f5b5-21d9-eab2a71b2224"><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; vertical-align: baseline; white-space: pre-wrap;"><i>NH House Science, Technology, and Energy Committee</i></span></p><br /><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt; text-align: center;"><br /></p><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt; text-align: center;"><span face="Roboto, sans-serif" style="font-size: large;"><span style="white-space: pre-wrap;"><b>Proposed HB 609: </b></span></span></p><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt; text-align: center;"><span style="font-size: large;"><span face="Roboto, sans-serif"><span style="white-space: pre-wrap;"><b>Three Seats at the Table, </b></span></span><b style="white-space: pre-wrap;">All for the PUC</b></span></p><div><span><br /></span></div><br /><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><a href="https://www.youtube.com/watch?v=a-mEXWtWGM4" style="text-decoration-line: none;"><span face="Roboto, sans-serif" style="color: #1155cc; font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; text-decoration-line: underline; text-decoration-skip-ink: none; vertical-align: baseline; white-space: pre-wrap;">https://www.youtube.com/watch?v=a-mEXWtWGM4</span></a></p><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; vertical-align: baseline; white-space: pre-wrap;">Excerpt starts at 1:04:41 (lightly edited for grammatical clarity)</span></p><br /><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; font-weight: 700; vertical-align: baseline; white-space: pre-wrap;"><br /></span></p><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; font-weight: 700; vertical-align: baseline; white-space: pre-wrap;">Rep. Rebecca McWilliams, House STE Committee:</span></p><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; font-weight: 700; vertical-align: baseline; white-space: pre-wrap;"><br /></span></p><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; vertical-align: baseline; white-space: pre-wrap;">"Follow-up question … so just to understand this…we're talking about three PUC Commissioners as the Site Evaluation Committee. That's it. And only two actually need to attend in order to move forward on any decision. That's the proposal. So I'm asking if we can change that makeup and add a couple more to get a little bit of variety here because the PUC is all appointees, and it doesn't necessarily reflect the interests of everyone in this room so I'm looking at the proposal for having the Attorney General appoint somebody to be a member or be involved. Perhaps that person could have a voting authority so that there's at least something beyond the PUC. I hear what you're saying about attendance and </span><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; vertical-align: baseline; white-space: pre-wrap;">perhaps different departments don't have the same interest and it's not a priority or they don't feel that they get enough money to compensate people to attend. All of those are legitimate concerns but fundamentally we want to have a Site Evaluation Committee that is </span><span face="Roboto, sans-serif" style="font-size: 11pt; white-space: pre-wrap;">neutral, that is independent, and so the concern is making sure that we have the bodies there that are voting who represent those interests to be neutral and independent, and I'm not convinced that three PUC Commissioners are truly neutral and independent because they’re appointees. So what I'm looking at is would you be open to an amendment or changes to get more members on that board [that would be going] from seven to three?"</span></p><br /><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; font-weight: 700; vertical-align: baseline; white-space: pre-wrap;">Mark Sanborn, Assistant Commissioner of NH DES:</span></p><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; font-weight: 700; vertical-align: baseline; white-space: pre-wrap;"><br /></span></p><p dir="ltr" style="line-height: 1.38; margin-bottom: 0pt; margin-top: 0pt;"><span face="Roboto, sans-serif" style="font-size: 11pt; font-variant-east-asian: normal; font-variant-numeric: normal; vertical-align: baseline; white-space: pre-wrap;">"Um, respectfully, no. That's the whole problem. More voices are only beneficial if more voices improve the process. In this case the key to a good permitting . . . process is ensuring all voices have the opportunity to speak to the issue, to the project in question, not that a board or . . . whoever is approving it are made up of all those voices. To me it's not important the number of folks who make up the adjudicative body, it's do the folks on that board have the expertise in terms of energy and permitting to make good decisions?"</span></p><br /><br /><br /></span>Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-6656577202161436602019-10-24T20:11:00.000-07:002019-10-24T20:11:46.301-07:00Rocks Estate hosts Northern Pass victory party (Littleton Courier, 10/23/2019)<div class="separator" style="clear: both; text-align: center;">
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<br />Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-12072041942969568872019-10-23T18:47:00.000-07:002019-10-23T18:47:09.177-07:00 Story Of Northern Pass ‘Resistance’ Preserved at Sugar Hill Historical Museum <div class="separator" style="clear: both; text-align: center;">
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<b>Story Of Northern Pass ‘Resistance’ Preserved at Sugar Hill Historical Museum </b><br />
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July 9, 2018<br />
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By News release<br />
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<i>Editor’s note: State utility regulators voted 7-0 on May 24 to reject a motion to reconsider their decision turning down the $1.6 billion, 192-mile Northern Pass Transmission project from Pittsburg to Deerfield. Project developer Eversource wanted the Site Evaluation Committee to vacate its February decision denying the application, reopen deliberations and consider conditions the utility said would mitigate its concerns. Eversource said at the time that it is not giving up the fight. </i><br />
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New historical resource opens under the auspices of the Sugar Hill Historical Museum, Sugar Hill, N.H. <br />
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With the support of grants from the “‘You Have Our Trust’ Fund of the NH Charitable Foundation” and an anonymous donor, the Sugar Hill Historical Museum will archive materials produced in opposition to the Northern Pass Transmission project from 2010 to 2018. The Town of Easton will provide additional storage space. <br />
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The two grants total $2,500. The money will be used to purchase curation materials to preserve the artifacts (e.g., fire-resistant storage containers, acid-free folders for photos and tubes for posters, etc.), for labor to catalogue and enter the accessions into a digital database. <br />
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The archive will preserve and document the story of the resistance to Northern Pass by “grassroots” citizens, as well as by conservation, environmental, recreational, and other non-governmental organizations, and by municipal and legislative groups. It will be available to researchers investigating the nature and history of this widespread, enduring opposition movement. The museum may also present exhibits of the archived materials from time to time. <br />
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Artifacts to be collected include: banners, buttons, bows, pins, bumper stickers, posters, lawn signs, flyers, post cards, tee shirts, hats, CDs, videos, and related items. Textual material includes newspaper clippings, magazine articles, letters to the editor, etc. Photos of events and of artifacts too large to store will also be preserved. <br />
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The archive will not conserve regulatory and other documents available online, e.g., public comments to the Site Evaluation Committee, and the museum reserves the right to decline and dispose of material that is redundant or not relevant. <br />
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The archive is now accepting donated materials. They may be submitted in person to the Museum during its open hours, Fridays and Saturdays, 11:00 am – 3:00 pm, Memorial Day to Columbus Day, or by U. S. mail. Digital resources should be submitted on a flash drive or memory stick, not by electronic mail, and labeled to indicate the contents. All donated materials should be accompanied by a statement indicating the name of the donor, a brief description of the artifacts, and the date of their creation. <br />
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The museum campus is located at 1401 Route 117 across from the Sugar Hill Post Office and next to the Town Hall and Library. The mailing address is Sugar Hill Historical Museum, P. O. Box 591, Sugar Hill, N.H. 03586. <br />
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For further information, contact Kitty Bigelow, Executive Director, Sugar Hill Historical Museum, at kittyh41@gmail.com; or Susan Schibanoff at burynorthernpass@gmail.com. <br />
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The Archive advisory committee also includes Nancy Martland, Sugar Hill, and Kris Pastoriza, Easton. <br />
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The Sugar Hill Historical Museum, a 501(c)(3) non-profit organization, also accepts financial contributions dedicated to supporting the curation of the Northern Pass Opposition Archive.<br />
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Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-56736760778448756802019-10-19T16:06:00.001-07:002019-10-19T16:06:55.624-07:00Party In Bethlehem: Northern Pass Opponents Celebrate Project’s Defeat<blockquote style="background-color: white; color: #201f1e; font-family: "Segoe UI", "Segoe UI Web (West European)", "Segoe UI", -apple-system, BlinkMacSystemFont, Roboto, "Helvetica Neue", sans-serif; font-size: 15px;" type="cite">
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Party In Bethlehem: Northern Pass Opponents Celebrate Project’s Defeat</div>
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BETHLEHEM — It was a party they’d been waiting to throw for nearly a decade.</div>
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A good number of people, though, thought that day – celebrating the defeat of Northern Pass, an event that took place Sunday at The Rocks Estate and drew hundreds of people from across the North Country and New Hampshire – might never arrive.</div>
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“I was very dubious this day would come,” said Nancy Martland, of Sugar Hill, one of the many area residents in the fight against the unpopular hydroelectric transmission line proposal with 100-foot-high towers that would have cut through Coos and Grafton counties. “I wanted it so badly, but it just seemed like it was an uphill battle.</div>
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Russ Cumbee, of Easton, likened the battle to David and Goliath.</div>
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“It was so unusual,” he said. “When did the people win? We were up against so much money and political influence.”</div>
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David Van Houten, of Bethlehem, said he hoped a celebration day would come, but didn’t think it would.</div>
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“I’ve been through enough of these struggles,” he said, adding about Northern Pass – “Delighted, though.”</div>
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Others held out hope during the many years of uncertainty, when they educated themselves and others and attended all or some of the 70 public hearings before the New Hampshire Site Evaluation Committee, which in February 2018 denied Northern Pass’s application, a decision that was upheld in July by the New Hampshire Supreme Court.</div>
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“I always felt it had to come,” said Kris Pastoriza, of Easton, also in the fight from the outset.</div>
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So did former state Sen. Jeanie Forrester, R-Meredith, who fought against the project from the statehouse, where she supported legislation to stop it.</div>
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“I always thought we would prevail,” said Forrester. “I am so proud of all the people because it took everybody working together to get this done. I think this is a model for people to look at for other things in New Hampshire that are not right.”</div>
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Susan Schibanoff, now of Sugar Hill and formerly of Easton and who kept residents up to date on Northern Pass happenings through the Bury The Northern Pass blog, said she couldn’t see how opponents would fail, even though “we were up against enormous odds.”</div>
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“They had all the money,” she said. “We didn’t have any. Not that we needed it. It was our passion and dedication.”</div>
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That passion and dedication overcame a transmission line that went through two iterations, an all overhead line and a mixed line that would have been overhead in Coos and buried for 50 miles along roads beginning in Bethlehem and through Franconia and Sugar Hill south to Bridgewater.</div>
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Eversource Energy, the Northern Pass parent company partnering with Hydro-Quebec, stood to gain some $10 billion in revenue and a $4 billion guaranteed profit during the 40-year term of the line, according to its federal filings.</div>
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Those in the North Country, though, argued the project would be nothing more than an “extension cord” through the North Country to southern New England and the company’s benefit would come with many detriments up north, including a scarred landscape in a region known for its scenic beauty, hits to the tourism industry and property values, and disruptions to downtowns and businesses during the construction of the buried line.</div>
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The SEC agreed, and in a unanimous decision concluded Eversource did not meet its burden of proving Northern Pass would not unduly interfere with the orderly economic development of the region.</div>
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Although claiming for years that their project would not impact property values, Eversource, after the SEC decision, conceded it just might and then offered a $25 million pot for those to dip into to compensate for drops in values.</div>
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By that point, however, the application period was already over and the project was in its last gasps.</div>
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When the state Supreme Court hammered the final nail in the Northern Pass coffin, Eversource withdrew its project a week later.</div>
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Sunday’s celebration that drew about 300 people occurred under a fall day with full sun and foliage still on the trees, and just a step and a holler from where the towers would have passed by The Rocks Estate.</div>
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“The power of the people prevailed,” said Martland, among the several opponents speaking to the crowd. “Give yourselves a round of applause.”</div>
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Jack Savage, the new president of the Society for the Protection of New Hampshire Forests – an opponent of Northern Pass that, as Eversource bought up properties for its route in Coos, would then block the route through conservation easements entered into with other property owners – spoke of the legacy of Northern Pass.</div>
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“Other grassroots groups around the country look at what we’ve done and are fighting for something they might not have fought for before,” he said.</div>
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Schibanoff said there were three phases to the grassroots fight – “education, education and education,” with opponents educating themselves, then the state, and finally the SEC.</div>
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During that time, many area residents attended the 70 evidentiary hearings by SEC in Concord, saw testimony from 154 witnesses, and became familiar with more than 2,000 project exhibits stemming from the more than 20,000-page application by Eversource</div>
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Forrester said the fight was truly a bipartisan effort, and thanked the late Executive Councilor Ray Burton, among the first to speak out, former U.S. Sen. Kelly Ayotte, R-NH, and local elected officials that include state Rep. Sue Ford, D-Easton.</div>
<div style="color: #1d2129; font-family: Helvetica, Arial, sans-serif; font-size: 14px; margin-bottom: 6px; margin-top: 6px;">
For Forrester’s role in the statehouse, it involved legislation, and the the first bill, sponsored by former state Rep. Larry Rappaport, R-Colebrook, prohibited private companies from using eminent domain to take private property for projects that, like Northern Pass, are elective.</div>
<div style="color: #1d2129; font-family: Helvetica, Arial, sans-serif; font-size: 14px; margin-bottom: 6px; margin-top: 6px;">
What followed then were three Senate bills that showed the feasibility of burying transmission lines in state-owned transportation corridors and changing the rules and the membership of the SEC, to include some members from the public, said Forrester.</div>
<div style="color: #1d2129; display: inline; font-family: Helvetica, Arial, sans-serif; font-size: 14px; margin-top: 6px;">
“It was nine years, but we did it,” she said.</div>
</div>
</div>
</blockquote>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-12682136662831936152018-07-06T04:54:00.003-07:002018-07-06T05:30:12.010-07:00Northern Pass Opposition Archive Opens in Sugar Hill, N.H.<br />
Grassroots Victory Over Northern Pass To Be Archived For Future Generations <br />
<br />
<div>
Wanted: Any Northern Pass Materials You Have <br />
<br />
Robert Blechl <br />
Caledonian Record</div>
<div>
July 6, 2018<br />
<br />
<br />
<br />
<br />
<a href="http://www.caledonianrecord.com/content/tncms/live/#1"><img src="https://bloximages.newyork1.vip.townnews.com/caledonianrecord.com/content/tncms/assets/v3/editorial/1/a0/1a09f241-8c19-5f03-8c98-375ed1e18212/5b3ec6259c81c.image.jpg" /></a><a href="http://www.caledonianrecord.com/content/tncms/live/#1"> </a><br />
<br />
<br />
<br />
The Sugar Hill Historical Museum is now collecting Northern Pass materials that for a permanent archive to document the successful fight by grassroots citizens. Left to right: Sugar Hill resident Nancy Martland, Easton resident Susan Schibanoff, and Easton resident Kris Pastoriza (all members of the archive advisory committe), and museum director Kitty Bigelow. (Photo by Robert Blechl)<br />
<br />
<br />
<b><br /><span style="font-size: large;">SUGAR HILL — Wanted: anything you have on Northern Pass</span></b><span style="font-size: large;">.</span><br />
<br />
<br />
The Sugar Hill Historical Museum will now house a permanent archive of all things Northern Pass-related - hats, T-shirts, road signs, videos, documents, and more - to educate future generations about the seven-year grassroots fight, provide instruction on how to confront similar projects in the future if they ever arise, and memorialize a consequential part of North Country history.<br />
<br />
The Northern Pass Opposition Archives is the brainchild of Easton resident Susan Schibanoff, who said in the course of opposing Northern Pass she tried to gather information on Easton’s 1970s battle against the ultimately defeated proposal for a four-lane highway through Franconia Notch, but found scant information.<br />
<br />
“That grassroots effort to fight wasn’t preserved,” she said. “But we can preserve these materials so the person who does want to write this history will have access to the material.”<br />
<br />
Currently at the Sugar Hill Historical museum are multiple versions of Northern Pass hats, T-shirts, and signs as well as lapel pins celebrating the documentary “The Power of Place” by Jerry Monkman and the Yankee Magazine article “My Roots Are Deeper Than Your Pockets.”<br />
<br />
“We also have endless buttons and bumper stickers,” said Schibanoff. “We have posters and lawn signs and will also take documents.”<br />
<br />
A request is now being made to residents of Grafton and Coos counties asking them to deliver what they have to the museum for posterity.<br />
<br />
“This is a museum and everything is carefully recorded,” said Northern Pass opponent and Sugar Hill resident Nancy Martland. “Every piece people give will become part of a digitized record.”<br />
<br />
The material, said Martland, will not be thrown willy-nilly into a box, but will be professionally archived.<br />
<br />
While some people may not want to part with what they have, leaving it with the museum will ensure it’s preserved and not some day discarded by a relative after a death or a move, said Schibanoff.<br />
<br />
The money for the Sugar Hill Historical Museum to archive is being provided through grants and an anonymous donor for the You Have Our Trust fund of the New Hampshire Charitable Foundation.<br />
<br />
The town of Easton will also provide additional storage.<br />
<br />
In addition to documenting the resistance of grassroots citizens, the archive will preserve the involvement of environmental, conservation, and non-governmental organizations, and make all the material available to researchers exploring the history of the opposition movement.<br />
<br />
The museum in Sugar Hill might also, from time to time, put the archived materials into exhibits.<br />
<br />
Other artifacts sought for collection are banners, bows, pins, post cards, CDs, and videos as well as magazine articles, newspaper clippings, and letters to the editor.<br />
<br />
Photographs of events and photographs of items too large to store will also be preserved.<br />
<br />
The museum will decline redundant materials.<br />
<br />
Materials that can be submitted in person during the museum’s open hours of 11 a.m. to 3 p.m. Friday and Saturday until Columbus Day.<br />
<br />
Items can also be sent via U.S. mail.<br />
<br />
Those donating documents or other materials electronically are asked to not email large files to the museum, but to put what they have on flash or thumb drives.<br />
<br />
Those donating are asked to include a statement with the name of the donor, a brief description of the artifact, and the date of its creation.<br />
<br />
The archive advisory committee includes Martland, Schibanoff, and Easton resident Kris Pastoriza.<br />
<br />
For more information, contact museum director Kitty Bigelow at kittyh41@gmail.com or Schibanoff at burynorthernpass@gmail.com.<br />
<br />
In February, after more than two years under review, the seven-member N.H. Site Evaluation Committee unanimously denied the Northern Pass application submitted by Eversource Energy.<br />
<br />
After 70 days of evidentiary hearings involving 154 witnesses and review of more than 2,000 exhibits, the SEC did not find that Eversource met its burden of proof in proving, by a preponderance of the evidence, that Northern Pass as proposed would not unduly interfere with the orderly economic development of the region.<br />
<br />
The 192-mile line would have been almost all above-ground in Coos County, where towers would have been about 100 feet tall, with more than 50 miles of buried line along state roads through towns from Bethlehem to Bridgewater.<br />
<br />
While it would have been a moneymaker for Eversource - $10 billion in revenue during the 40-year term of the line, including a $4 billion in guaranteed profit, according to the company’s federal filings - opponents argued Northern Pass would have destroyed scenic views and property values, would have hurt the tourism industry, and would have negatively impacted small businesses during the burial portion of construction in the roadways outside their front doors.<br />
<br />
Scores of North Country residents testified during the SEC hearings and many more stayed mobilized for more than half a decade to defeat Northern Pass.<br />
<br />
On May 24, the SEC denied a request by Eversource to resume the deliberations the committee ended Feb. 2.<br />
<br />
Once the May denial is formalized in a written order, Eversource can appeal the SEC’s decision to the N.H. Supreme Court.<br />
<br />
Opponents are confident the SEC decision is sound and will withstand any appeal by Eversource.<br />
<br />
The other reason to get the word out now about the Northern Pass archive is because when people are in the thick of a fight they are not concerned with saving what they have, said Schibanoff, who four years into the Northern Pass fight had accumulated so much material she began culling it.<br />
<br />
In addition to the Franconia Notch Parkway fight, Martland said a similar Northern Pass fight, one that involved a proposed above-ground transmission line slated for scenic areas of upstate New York that was also stopped by citizens, likewise wasn’t well-documented.<br />
<br />
Martland doesn’t want the same fate to befall the battle of Northern Pass.<br />
<br />
“Please help us grow this archive,” said Schibanoff.<br />
<i><br /></i>
<i>The Sugar Hill Historical Museum, a non-profit 501(c)(3) organization, is located at 1401 Route 117, across from Harman's Cheese and the Sugar Hill Post Office. The mailing address is Sugar Hill Historical Museum, P.O. Box 591, Sugar Hill N.H. 03586. Museum open hours are 11:00 a.m. to 3:00 p.m., Fridays and Saturdays, Memorial Day to Columbus Day. Contact Executive Director Kitty Bigelow at kittyh41@gmail.com or Susan Schibanoff at burynorthernpass@gmail.com for further information concerning the Archive project. </i></div>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-15125431341178324542018-02-04T07:29:00.000-08:002018-02-04T07:29:34.334-08:00Northern Pass: Municipal Views<span style="font-size: large;"><b>Northern Pass: Municipal Views</b></span><br />
<br />
<i>"This application for a Certificate of Site and Facility is unprecedented to the extent that it
is a private merchant transmission line that is one of the most controversial and opposed energy
projects in New Hampshire history. There has never been an approval of a high voltage
transmission line energy project in which the vast majority of the host municipalities and
unincorporated places have intervened and actively opposed a proposed project." </i>Northern Pass Docket 2015-06: <u><a href="https://www.nhsec.nh.gov/projects/2015-06/final_brief/2015-06_2018-01-12_final_brief_jt_muni_redacted.pdf">Post Hearing Memorandum of Municipal Groups 1 South, 2, 3 South, and 3 North</a></u>, January 12, 2018, p. 1.<br />
<br />
For a 2011-2014 archive of Municipal Views, click <a href="http://burynorthernpass.blogspot.com/2014/03/town-meeting-warrant-articles-on.html">here.</a><br />
<br />
<br />
<br />
<br />
<table align="center" cellpadding="0" cellspacing="0" class="tr-caption-container" style="margin-left: auto; margin-right: auto; text-align: center;"><tbody>
<tr><td style="text-align: center;"><a href="https://4.bp.blogspot.com/-tyrg_xAElwY/WnckpzvNs4I/AAAAAAAAA8o/l7o4UTG8t6oxC0nCFou9V6aHHQKOC1e7gCLcBGAs/s1600/MuniVues_Easton.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="1600" data-original-width="1600" height="400" src="https://4.bp.blogspot.com/-tyrg_xAElwY/WnckpzvNs4I/AAAAAAAAA8o/l7o4UTG8t6oxC0nCFou9V6aHHQKOC1e7gCLcBGAs/s400/MuniVues_Easton.jpg" width="400" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;"><b>EASTON (2/3/2018)</b></td></tr>
</tbody></table>
<br />Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-44766614526220324522017-12-16T05:21:00.000-08:002017-12-16T05:31:31.276-08:00Northern Pass Business Directory Stirs Some Controversy<br />
<br />
Northern Pass Business Directory Stirs Some Controversy<br />
<br />
<br />
Robert Blechl <br />
Caledonian Record<br />
December 16, 2017<br />
<br />
Wrong names, closed businesses, and ones who say they never signed up and oppose the project - all can be found on the recently released Northern Pass business directory, which Eversource Energy had wanted to keep confidential at this point.<br />
<br />
Of the 208 businesses on it, many did sign up, with some saying they don’t necessary support Northern Pass, but if the line is ever approved it would benefit their enterprise and other small, local businesses that would see traffic from work crews building the line.<br />
<br />
Others, however, were surprised and perplexed, and some angry, to find themselves on it and are now trying to get off a directory they say they never registered for and that conveys the impression they support the project when they don’t.<br />
<br />
On Friday, Eversource/Northern Pass spokesman Martin Murray said, “Support of the project was never asked for nor required of any business to be listed, and all the businesses in the directory did previously indicate their respective agreement to be listed.”<br />
<br />
Some business owners in the North Country said there was no such agreement.<br />
<br />
One is Kate Foley, who runs Cold Mountain Cafe in Bethlehem.<br />
<br />
“We do not support the Northern Pass and are outraged that we were added to the list,” she said in a Dec. 3 letter to Tom Getz, attorney for Eversource Energy, which is proposing the transmission line. “In fact, we are horrified to be connected to this endeavor in any way.”<br />
<br />
She asked that Cold Mountain Cafe be removed and requested a written apology from Eversource “to show all our customers and people of our community that we are not supporting the Northern Pass.”<br />
<br />
Getz issued a response letter, saying a “community outreach team member” spoke with a “Kate” in 2015 about participating in the business directory.<br />
<br />
Foley, however, said no such contact occurred. Her mother, Coleen Foley, said the same.<br />
<br />
In his response, Getz, who said Cold Mountain Cafe will be removed, said the list was created to ensure local businesses would benefit from the project.<br />
<br />
For some, though, that doesn’t explain how their businesses - more than a half dozen the Caledonian-Record spoke with, from Littleton to Pittsburg - became listed on a directory they never sought to be on.<br />
<br />
“We did not give them any kind of permission for that,” said Tom Caron, co-owner of Rainbow Grille and Tavern in Pittsburg. “No one stopped by to my knowledge. We came out against Northern Pass, in a letter written under Tall Timber Lodge, so I’m not sure how it came to be.”<br />
<br />
Another is Le Rendez Vous French Bakery, Colebrook, owned by Verlaine Daeron and Marc Ounis.<br />
<br />
“We never signed up, but we have our name on the list,” Daeron said Friday.<br />
<br />
They did receive a friendly email from Eversource on Thursday stating their name would be removed, she said.<br />
<br />
“We prefer not to be associated with Northern Pass,” said Verlaine. “We are against that.”<br />
<br />
In Littleton, there is The French Sisters Bakery.<br />
<br />
Owner Patricia Ann Tilton said her husband, Rick, learned of their business’s listing after the N.H. Site Evaluation publicly released the directory on Nov. 20. The implication, she said, was that French Sisters supports the project.<br />
<br />
“That’s not the case at all,” said Tilton. “I don’t know how they got our names and how this came about.”<br />
<br />
Rodney Stone, who runs Twisted Wrench Auto Repair in Bethlehem, said he also never signed up and it’s a mystery to how he got on there.<br />
<br />
On the directory, too, is the Spare Time Pizza Pub, in Colebrook, whose name was changed three years ago to Strike Zone Pizza, and Colebrook House Motel and Restaurant, which closed several years ago.<br />
<br />
Another entry is the Dancing Bear Pub in Colebrook, which closed in 2015 and is now the location of Black Bear Tavern.<br />
<br />
“Dancing Bear Pub hasn’t existed for 2 1/2 years,” said Black Bear Tavern owner Rick Nadig, who said he is not in favor of the project. “Personally, I don’t care whether I’m in the directory or not. But if you’re going to put out a directory, make sure the information is correct.”<br />
<br />
Heidi Milbrand, who runs Pleasant View B&B in Bristol, found out from a Bristol town representative.<br />
<br />
“I never signed up for anything,” she said. “I’ve called [Northern Pass] twice and spoken with somebody who assured me my name would be removed, but it hasn’t been removed as of yet.”<br />
<br />
Doug Kenney, who runs Crazy Horse Family Campground in Littleton, said the previous campground owner, when a few years ago it was called Crazy Horse Campground, could have had something to do with the inclusion of the latter name.<br />
<br />
“We didn’t put our names on it,” said Kenney.<br />
<br />
Others, however, did sign up, including the seasonal Barron Brook Inn, in Whitefield.<br />
<br />
Owner Beth Cape, a member of Northern Gateway Regional Chamber of Commerce, said the inn could provide lodging to construction workers.<br />
<br />
“If you own a business, you can’t discriminate,” she said. “That doesn’t mean we support it, but we are a hospitality business, and if you look up the word hospitality, you have to open your doors to all … My job is to help businesses and promote our business. There is some trickle-down effect to local businesses.”<br />
<br />
Cape called Northern Pass a “tough situation” and said if the line was going near her property she would not be happy.<br />
<br />
Shawn Cote, of LL Cote sports center in Errol, also said he chose to be on the directory.<br />
<br />
“Being a businessman, if it’s coming through I’d just as soon be on the good side of things than the bad,” he said. “There will be plenty of people around and we definitely need some business in this area.”<br />
<br />
The city of Franklin, which would have a DC-to-AC converter station and is the only municipality out of the 31 communities the line would run through that is on record supporting Northern Pass, has 46, or nearly a quarter, of the 208 directory listings.<br />
<br />
Franconia, Sugar Hill, and Plymouth, all hotbeds of opposition, have no listings.<br />
<br />
For Cold Mountain Cafe, Coleen Foley said when she asked representatives of Northern Pass how businesses get on the directory, she was told they have to register.<br />
<br />
“That is not certainly anything we did,” she said.<br />
<br />
Murray declined to recount the process of how businesses were contacted, who from Northern Pass visited area businesses, and what was said to them about the directory.<br />
<br />
He also declined to say how many businesses to date have contacted Eversource requesting removal of their names and if the N.H. Site Evaluation Committee was also a target audience for the directory to show business support for the project.<br />
<br />
The Northern Pass business directory web page has a prompt for owners of lodging establishments, restaurants, gas stations, convenience and hardware stores and other businesses to actively sign up if they want to be included.<br />
<br />
In testimony before the SEC, lead Northern Pass project manager Sam Johnson, when asked about economic impacts, said between 200 and 300 businesses registered with Northern Pass through a jobs hot line.<br />
<br />
He said businesses have to register to be on the list and, when notified, are directed to a web site to put their name in.<br />
<br />
“That, in effect, is the way we do it,” said Johnson.<br />
<br />
It is completely sensible to produce a listing of businesses that are available to provide services for what would be some 2,000 Northern Pass construction workers, said Murray.<br />
<br />
Eversource sought confidential treatment of listed businesses because of concern for their privacy, he said.<br />
<br />
“We will honor the request of any business who does not wish to be listed on the directory when it is actually published and disseminated at the time construction begins,” said Murray.Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-87344175860588763462017-10-14T12:40:00.002-07:002017-10-14T12:52:25.381-07:00CLF's Objection to WMNF's Draft ROD (Oct. 13, 2017)<div style="text-align: center;">
Conservation Law Foundation's Objection to WMNF's "Draft Record of Decision" on Northern Pass</div>
<div style="text-align: center;">
<br /></div>
<div style="text-align: center;">
Synopsis with Excerpts<br />
<i><br /></i>
<i>Contact <a href="mailto:e-info@clf.org">e-info@clf.org</a> for a copy of the full 35-page text with documentation and references.</i></div>
<div style="text-align: center;">
<br /></div>
<div style="text-align: center;">
<br /></div>
<div style="text-align: center;">
(For SPNHF's objection, click <a href="http://burynorthernpass.blogspot.com/2017/10/spnhfs-objection-to-draft-rod-oct-13.html">here</a>.)</div>
<div style="text-align: center;">
<br /></div>
<div style="text-align: center;">
(For AMC's objection, click <a href="http://burynorthernpass.blogspot.com/2017/10/amcs-objection-to-wmnf-draft-rod-oct-13.html">here</a>.)</div>
<div style="text-align: center;">
<br /></div>
<div style="text-align: left;">
October 13, 2017 </div>
<div style="text-align: left;">
By Electronic Delivery (objections-eastern-region@fs.fed.us) & Overnight Delivery (FedEx) </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Mary Beth Borst, Reviewing Officer </div>
<div style="text-align: left;">
USDA Forest Service, Eastern Region </div>
<div style="text-align: left;">
626 East Wisconsin Avenue, Suite 700 </div>
<div style="text-align: left;">
Milwaukee, WI 53202 </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Re: Objection to U.S. Forest Service Draft Record of Decision, Northern Pass
Transmission Line Project (White Mountain National Forest, Grafton County, New
Hampshire) </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Dear Ms. Borst: </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Conservation Law Foundation (“CLF”) hereby objects to the Draft Record of Decision
published on September 1, 2017 by the U.S. Forest Service, Eastern Division, White Mountain
National Forest (Grafton County, New Hampshire) authorizing use and occupancy of National
Forest System lands by Northerrn Pass Transmission, LLC for the construction, operation and
maintenance of its proposed electric power transmission line crossing portions of the White
Mountain National Forest. . . .</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
CLF objects to the Draft Record of Decision on the ground that it is premised on a
grossly deficient NEPA analysis and, further, that it is contrary to the public interest. With the
exception of one issue that has arisen as a result of concerns expressed by the U.S.
Environmental Protection Agency by letter dated September 26, 2017, the bases for CLF’s
objection have been raised by CLF in specific written comments submitted during the NEPA
process and are set forth below.</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
I. The FEIS Fails to Establish that the Project is Needed in the Context of Other
Regional Developments and Current Grid Management Capabilities</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
The Draft Record of Decision discusses the purported “Project Objectives” of the the
Northern Pass transmission line as addressing electricity diversity, low carbon electricity supply,
and non-intermittent power supply. Draft Record of Decision at 3-5. It then proceeds – in
explicit reliance on the FEIS, to review the merits of the project on the basis of those objectives.
Importantly, however, the FEIS (and by extension the Draft Record of Decision ) does not
establish that there is a specific need for or benefit to the Project, in the context of other regional
developments and capabilities. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
The FEIS and Draft ROD have failed to analyze the need for Northern Pass in the context
of other major transmission and generation development underway and proposed throughout the
region. There is a range of solutions available to meet each of the three project objectives
enumerated in the FEIS and Draft ROD, individually or in combination. The 35 proposals
submitted in response to the Massachusetts Request for Proposals (“RFP”), some of which
contain multiple bids or project alternatives, underscore this fact. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Among the RFP bids, “like-competitors” to Northern Pass may include: </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
1. Granite State Power Link (Grid America/National Grid): 1200-MW line from
Quebec to VT & NH + 500-804 MW wind + uncontracted capacity for hydro/other. </div>
<div style="text-align: left;">
2. New England Clean Power Link (HQ & TDI): 1000-MW line from Quebec to VT +
1000 MW hydro/wind. </div>
<div style="text-align: left;">
3. Atlantic Link (Emera): 1000-MW subsea transmission line from New Brunswick to
MA + wind/hydro. </div>
<div style="text-align: left;">
4. Maine Clean Power Connection (CMP-Avangrid): 345 kV line through ME + multiple
renewable energy proposals + energy storage. </div>
<div style="text-align: left;">
5. New England Clean Energy Connect (CMP-Avangrid): 1200-MW line from Quebec
to ME + wind/hydro. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
The projects identified above could serve the objectives of enhancing access to diverse,
low-carbon, and non-intermittent energy supplies, and like Northern Pass are designed to provide
a substantial amount of total energy to the New England region.4
Although the FEIS references
some of these projects, such as Granite State Power Link and New England Clean Power Link,
the FEIS and Draft ROD fail to adequately address them due to the FEIS’s unlawfully narrow
purpose and need statement (discussed infra at Part II). </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
At the same time, it is important to note that there is no particular magic to the size of the
Northern Pass project or like-sized competitors. For example, there is not necessarily an intrinsic
benefit to Massachusetts accepting one large bid as opposed to two or three (or more) smaller
proposals. Indeed, there may be some benefit in accepting a combination of bids, whether that
benefit be hedging against failure to build, minimizing overall environmental impact, additional
resource and geographic diversity, or reducing the need for the most lengthy transmission lines.
DOE fails to address these issues. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
The FEIS also fails to meaningfully address the extent to which rooftop solar, energy
storage and demand-side resources, in combination with energy efficiency, could defer, reduce,
or eliminate the need that the FEIS and the Forest Service identify for Northern Pass. As
discussed in more detail later in these comments, these resources are increasingly prominent in
New England and have played an important role in constraining demand, cost, and the need for
new large-scale generation resources. Although the FEIS attaches a technical report that
indicates increased regional reliance on these resources,5
it does not adequately address these
resources in drawing conclusions on the preferred alternative. The FEIS declines to address
them in detail. . . .</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
There are no other grounds to assume that Northern Pass is needed to maintain reliability.
When new transmission is needed to support the reliability of the electric grid in New England,
the cost of that transmission is shared among all users and such projects are considered reliability
transmission upgrades (RTUs).7
Northern Pass is not a reliability transmission upgrade, and as
acknowledged in the FEIS, it has never been advanced as a reliability transmission upgrade. It is
not needed to support the stability of the electricity grid and it is not a project for which all
utilities in the region will pay based on their share of demand on the grid. Even while
acknowledging that the Project is elective rather than reliability-based, the FEIS erroneously
seeks to characterize Northern Pass as needed to ensure reliability in the region.</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
II. The Purpose and Need Statement is Unlawfully Narrow, Establishing a Self-
Fulfilling Prophecy in Favor of the Project and Unlawfully Constraining the
Alternatives Analysis </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
. . . .</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
For these reasons, and for the reasons set forth in CLF’s prior comments, the FEIS is
based on an unlawfully constrained purpose and need statement, rendering unlawful any Forest
Service Record of Decision premised upon the FEIS. Separate and apart from its reliance on the
FEIS, the unlawfully narrow purpose and need statement adopted by the Forest Service in its
Draft Record of Decision further renders unlawful any final decision granting a special use
permit.</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
III. The EIS Alternatives Analysis is Flawed as a Matter of Law </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
A. The FEIS’s Alternatives Analysis is Fatally Flawed because it is Premised on an
Unlawfully Narrow Purpose and Need Statement. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
B. The FEIS’s Alternatives Analysis is Deficient Because It Excludes From Detailed
Analysis a Number of Reasonable Alternatives </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
(1) The FEIS is Deficient for its Failure to Include Power Generation
Alternatives among the Reasonable Range of Alternatives For Detailed
Analysis </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
(2) The FEIS is Deficient for its Failure to Include Other Transmission Projects
among the Reasonable Range of Alternatives for Detailed Analysis </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
(3) The FEIS is Deficient for its Failure to Consider Demand-Side Management,
Including Energy Efficiency, among the Reasonable Range of Alternatives
for Detailed Analysis </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
(4) The FEIS is Deficient for its Failure to Include a Detailed Analysis of
Underground Transmission Cable in Railroad Rights-of-Way</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
The FEIS specifically eliminates from its reasonable range of alternatives the burial of
transmission cable in railroad rights of way. FEIS at 2-51 to 2-52. While the FEIS includes brief
additional discussion of how DOE arrived at its determination to exclude the use of railroad
rights of way from detailed analysis, it does nothing to cure the deficiencies identified by CLF in
its comments on the DEIS/SDEIS. Specifically, the FEIS explains that DOE considered “the
entire range of active, inactive and abandoned railroad ROWs” and then, “[b]ased on all these
permutations,” assembled a combination of rights of way to form the single route that was
considered and rejected. FEIS at 2-51. Rather than identifying a single route and then
eliminating that route from consideration as a result of space constraints, the FEIS could have
and should have assessed other potential right-of-way combinations / routes to determine their
feasibility, including but not limited to combinations incorporating railroad right-of-way in
Vermont. Its failure to do so render the FEIS and the Forest Service’s reliance thereon deficient
as a matter of law. CLF hereby reiterates and incorporates by reference its prior comments
related to DOE’s improper assessment of railroad rights of way. See CLF’s Comments on
DEIS/SDEIS at 20-22.</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
(5) The FEIS is Deficient for its Failure to Include a Detailed Analysis of
Alternative Border Crossings</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
C. The FEIS is Deficient for its Failure to Adequately Assess Certain Alternatives
Selected for Detailed Analysis</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
(1) The FEIS Is Deficient Because It Fails to Include Meaningful Analysis of
the No-Action Alternative</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
(2) The Analysis of Underground Cable Alternatives in Highway Corridors
is Deficient </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
CLF appreciates DOE’s and the Forest Service’s consideration of I-93 for purposes of
burying HVDC cable and its determination that, as considered within certain enumerated
alternatives, I-93 presents a viable option. With specific regard to I-93, however, CLF reiterates
its position that the EIS should have analyzed an alternative that relies on burial in the I-93
corridor north of Franconia notch, into Vermont, with continued burial in the I-91 transportation.</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
It also should have considered use of I-91 in Vermont in combination with the use of
I-89 and/or railroad rights of way, such as those that would allow access from the west and
northwest. Highway corridors provide an opportunity to avoid the use of overhead transmission
lines and their long-term impacts and potentially at lower cost than other routes not located on
transportation corridors. The FEIS, and decision-makers relying on it, have not adequately
assessed the important opportunity highway corridors could serve. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
D. The Alternatives Analysis Fails to Support a Decision that Complies with the
Clean Water Act’s “Least Environmentally Damaging Practicable Alternative”
Requirement</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
IV. The FEIS is Deficient as a Matter of Law because its Impact Analysis Entirely Fails
to Address Certain Impacts and Inadequately Addresses Others </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
A. The FEIS is Deficient Because it Fails to Assess the Impacts of Generation
and Transmission in Canada </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
B. The FEIS is Deficient for Its Failure to Assess Environmental Justice
Issues Pertaining to Indigenous Populations </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
As referenced above, on August 30, 2017 the Conseil des Innus de Pessamit submitted
comments to DOE describing numerous long-standing and continuing adverse impacts on the
Pessamit Innu First Nation caused by the development and operation of Hydro Quebec’s
hydroelectric infrastructure, and raising concerns about further impacts associated with the
continued development of such infrastructure. The FEIS fails to assess the reasonably
foreseeable impacts on the Pessamit Innu First Nation, including but not limited to
environmental justice issues.44 The FEIS presumably omitted this environmental justice
assessment on grounds that the Pessamit Innu First Nation is located in Canada. For the reasons discussed in Part IV.A., however, the extraterritorial location of the Pessamit Innu First Nation
does not excuse DOE from analyzing and discussing the impacts on this community. The failure
to assess environmental justice issues related to the Pessamit Innu First Nation renders the FEIS
– and any decision that relies on it – deficient as a matter of law.</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
C. The FEIS is Deficient Because it Fails to Consider Negative Impacts on
the Development of Renewable Energy and Energy Efficiency in New
England </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
D. The FEIS is Deficient because it Fails to Accurately Assess Either the
Value of New Hampshire’s Viewsheds or the Impacts of the Project on
those Viewsheds </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Consistent with the DEIS, the FEIS accurately concludes that New Hampshire’s North
Country has a high intrinsic visual quality. FEIS at 3-67. The FEIS also concludes that the area
is characterized by “a very low level of development” and a low population density. Id.
Consistent with this low population density and low level of human development, the FEIS
enumerates a large number of parks available for public use in the areas of scenic concern in the
North Country: White Mountain National Forest, Weeks and Dixville Notch State Parks,
Coleman, Cape Horn, Percy and Nash Stream State Forests, Connecticut River National Byway,
Moose Path Trail, Presidential Range Tour, White Mountain Trail Northern Loop, Pontook
Reservoir, Lancaster Town Forest, and Kauffman Forest. Id.
45
However, the technical report to the FEIS erroneously relies on population data as the
basis for conclusions as to the overall visual impact of the proposed project, including its impacts
on the North Country. Section 2.4.2.5 of the Visual Impact Assessment explains that, in the
absence of available data on the usage of the scenic or recreational resources in New Hampshire, DOE’s consultant, T.J. Boyle Associates, assessed viewer exposure based on population
numbers, stating:
Data regarding potential viewers are generally not available for scenic or
recreation resources in New Hampshire, therefore scenic concern cannot be
weighted by the number of recreation viewers . . . potential visual exposure is
approximated as a function of population density based on 2010 U.S. Census
block-level data.
Visual Impact Assessment at 48.
Applying this approach to the North Country, the Visual Impact Assessment falsely
concludes that viewer impacts will be low because there are few residents (at 93):
Just over half of the Northern Section has no residents and another 40 percent
has very low population density. In most of the area, it is unlikely there will be
many viewers affected by a visual change. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
As CLF indicated in its comments on the DEIS/SDEIS (pages 31-32), assessing viewer
exposure based on U.S. Census data is an arbitrary and unsupportable approach due to the fact
that scenic recreational areas are by definition areas that do not entail habitation. This approach
leads to particularly dramatic errors when applied to less developed areas such as the North
Country, which serves as a region-wide resource for outdoor activities and appreciation of the
natural environment.46 The North Country’s intrinsic visual quality stems from the fact that it
has a low population density and level of development, but a high number of parks and natural
viewscapes accessible to the general, non-resident public. The FEIS nevertheless disregards
visitor data altogether, relying solely upon resident population to draw conclusions as to viewer
exposure. To ignore the fact that New Hampshire sees upward of 34 million travelers and
tourists annually – more than twenty five times the state’s population – is illogical and arbitrary.47 </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
DOE’s explanation that the value of scenic sensitivity used is the “greater of scenic
concern or viewer exposure, not the average,” and that “low viewer exposure in the Northern
Section and the WMNF, for example, does not lower the scenic sensitivity of these areas” is
inadequate.48 Using this methodology does ensure that undervaluing viewer exposure will not
lower scenic sensitivity below the rankings for scenic concern. However, without conducting an
appropriate analysis it is impossible to know whether accurate viewer exposure data might
increase the study’s ratings for scenic sensitivity, a very real possibility given the number of
visitors to the state each year. The use of U.S. Census information as a substitute for usage data
inevitably leads to a substantial undervaluation of visual impacts, and the FEIS is therefore
defective and must be corrected.</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
DOE’s viewshed impacts analysis remains infected with other unsupported conclusions.
DOE’s explanation that “experiences, not places, are rated” in Table 9 of the Visual Impact
Assessment (at 47-48) fails to address these deficiencies.49 Table 9 rates the importance of
scenery to the experience of various activities known to take place in New Hampshire. The
Visual Impact Assessment contains arbitrary and unsupported conclusions including: </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
that although campgrounds, picnic areas, and recreation resorts are often selected
based on their scenic locations, they do not rate “very high” for importance of
scenery; </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
that parks are not valued highly for their scenic value; </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
that areas used for activities such as skiing, swimming, boating, fishing, and
golfing are not highly valued for their scenic quality because of the attention they
require to an activity;
that the setting is “non-contributing” to the experience of rockhounding; and </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
that special events (presumably including weddings and other celebrations) are
held indoors, and therefore the scenic quality of the environment is very low value
to those activities.
Among other things, it is widely known that celebrations such as weddings are often held
outside,50 and the scenic environment can be a critical element of the experience. That the visual
impacts analysis upon which DOE relies continues to fail to engage either common sense or objective data to draw conclusions as to the importance of visual quality is in clear error,
rendering the FEIS and decisions that rely on the FEIS grossly deficient. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
E. The Socioeconomic Technical Report Contains False and Unsupported
Assumptions that Infect Core Conclusions of the FEIS</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
F. The FEIS Fails to Identify and Consider Impacts on Landscape-Level
Historical and Cultural Resources </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
G. The FEIS Fails to Comprehensively Assess Cumulative Impacts</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
V. The FEIS and the Forest Service’s Draft Record of Decision are Contrary to the
Public Interest</div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
VI. Conclusion
CLF objects to the Forest Service’s Draft Record of Decision on the grounds that, as set
forth above an in previously submitted written comments, it is premised on a legally deficient
Environmental Impact Statement and, further, because the Draft Record of Decision is contrary
to the public interest. CLF urges the Forest Service not to finalize its Draft Record of Decision
unless and until all of the above legal deficiencies have been corrected, with the ability for
further public comment, and to deny the requested special use permit as contrary to the public
interest. </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Respectfully submitted, </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Tom Irwin </div>
<div style="text-align: left;">
Vice President & CLF New Hampshire Director </div>
<div style="text-align: left;">
Conservation Law Foundation </div>
<div style="text-align: left;">
27 North Main Street
Concord, NH 03301 </div>
<div style="text-align: left;">
tirwin@clf.org </div>
<div style="text-align: left;">
(603) 573-9139 </div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
<br /></div>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-44726639760474153462017-10-13T18:09:00.000-07:002017-10-14T12:47:13.040-07:00SPNHF's Objection to WMNF's Draft ROD (Oct. 13, 2017)<br />
<br />
<div style="text-align: center;">
<b>SPNHF's Objection to WMNF's "Draft Record of Decision" on Northern Pass</b></div>
<div style="text-align: center;">
<b><br /></b></div>
<div style="text-align: center;">
<b>(Read the Appalachian Mountain Club's objection <a href="http://burynorthernpass.blogspot.com/2017/10/amcs-objection-to-wmnf-draft-rod-oct-13.html">here</a>.)</b><br />
<b><br /></b>
<b>(Read the Conservation Law Foundation's objection <a href="http://burynorthernpass.blogspot.com/2017/10/clfs-objection-to-wmnfs-draft-rod-oct.html">here</a>.)</b></div>
<br />
October 13, 2017 <br />
<br />
<div>
Sent by Email 10/13/17 to: objections‐eastern‐region@fs.fed.us <br />
<br />
Mary Beth Borst, Reviewing Officer </div>
<div>
USDA Forest Service <br />
626 East Wisconsin Avenue, Suite 700 <br />
Milwaukee, WI 53202 <br />
<br />
Dear Ms. Borst: <br />
<br />
This letter serves as a formal response to the Draft Record of Decision (ROD) issued August 31, 2017 by Thomas G. Wagner, then Supervisor of the White Mountain National Forest (WMNF), on the matter of issuing a Special Use Permit (SUP) for the Northern Pass Transmission project to use and occupy land owned by the Forest Service. <br />
<br />
The Forest Society was founded in 1901, in part to assure that the large scale liquidation of New Hampshire forests in the White Mountains region never happened again. With the active engagement of the Forest Society, the Weeks Act was adopted by the U.S. Congress in 1911, creating the authority for the US Forest Service to acquire private lands for the purpose of protecting the headwaters of major river systems east of the Mississippi River. Ever since the first parcel of land was acquired for the WMNF in 1918 in the town of Benton, New Hampshire, the Forest Society has been an active partner with the Forest Service as “the people’s forest” in the White Mountains matured. We greatly value this one hundred years of collaboration. We believe that the partnerships the WMNF has established with municipalities, land owners, the forest products industry, state government and other non‐ government organizations like ours have been critical to what today makes the WMNF a flagship in the national forest system. <br />
<br />
The Forest Society is filing this objection as constructive criticism from a 100 year‐old partner. We have three major concerns, each detailed below, and each accompanied by a suggested remedy for curing the deficiency cited. The Forest Society concludes that the Draft ROD issued August 31 should be remanded to the WMNF Forest Supervisor for reconsideration. <br />
<br />
1. Faulty and Incomplete Consideration of Available Alternatives <br />
<br />
REASON FOR OBJECTION: The draft ROD fails to consider alternatives which could transmit electric power from Hydro‐Quebec to consumers in New England with little or no impact on the White Mountain National Forest. For this reason alone, the Regional Forester should return the draft ROD to the WMNF Supervisor for reconsideration. <br />
<br />
As the draft ROD notes, the Final Environmental Impact Statement (FEIS) is one factor in the larger set of issues that inform a Record of Decision. The Supervisor has the capacity to look beyond the FEIS to fully inform his/her decision. Nothing in the National Environmental Policy Act limits the Forest Supervisor to the alternatives considered in the FEIS. The draft ROD cites market supply considerations in support of its claim that the project meets three primary needs for electricity in New England: diversity of supply, low‐carbon supply, and non‐ intermittent supply. Yet, the draft ROD avoids applying market considerations to its consideration of alternatives. <br />
<br />
For example, one market alternative is the New England Clean Power Link (NECPL) project, which would bring the same volume of electricity from Quebec to the New England grid without crossing any land in New Hampshire. This project has all the needed federal and state permits to proceed to construction. It would completely avoid the White Mountain National Forest, and would also avoid all of the unreasonable adverse impacts that Northern Pass as proposed would have on New Hampshire. <br />
<br />
Another market alternative is the Granite State Power Link project, which would bring 1200 megawatts of electricity to the New England grid using existing transmission line infrastructure in New Hampshire. It would not require a Forest Service SUP, and would avoid all of the unreasonable adverse impacts that Northern Pass as proposed would have on New Hampshire (including the WMNF). <br />
<br />
These two projects are among the 46 proposals for a long term renewable electricity supply contract currently under consideration by the State of Massachusetts. Of these 46 proposals, at least six propose to use Hydro‐Quebec as a supplier, including the NECPL project. Of the 46, only Northern Pass requires a Special Use Permit from the WMNF. If the marketplace is actively considering market alternatives to Northern Pass, it would seem entirely rational for the WMNF Supervisor to consider them as well in rendering this decision. <br />
<br />
An added concern regarding the incomplete consideration of alternatives is the failure of the FEIS itself to look at alternative crossings of the international boundary. For purposes of the Department of Energy’s review under NEPA, the DOE should have considered more than one border crossing to fulfill its NEPA obligation to look at practicable alternatives for the decision DOE is charged with making on the Presidential Permit. Had DOE considered other border crossings in its review, and not limited its consideration to the sole crossing the applicant requested (in Pittsburg, NH, at Hall’s Stream), it is very likely that corridor alternatives completely bypassing the White Mountain National Forest may have been more thoroughly considered in the NEPA review process. For example, a crossing in Derby, Vermont, using the Interstate 91 and Interstate 93 corridors would result in an alternative that would have significantly less impact on the WMNF than the alternative proposed by the draft ROD. <br />
<br />
REMEDY: Return the draft ROD to the WMNF Supervisor for reconsideration of alternatives that would have no impact or substantially less impact to the White Mountain National Forest than the alternatives supported by the draft ROD. 2. <br />
<br />
Faulty Assessment of Interstate 93 Corridor In Decision Rationale <br />
<br />
Reason for Objection: The draft ROD’s rationale goes to some length to debunk the feasibility of using Interstate 93, particularly through Franconia Notch, while simultaneously acknowledging that burying the line in the Interstate 93 corridor would have significantly less impact on the WMNF than the specific alternatives the draft ROD recommends be the subject of a Forest Service SUP. <br />
<br />
This analysis is faulty on several counts: <br />
<br />
The land in Franconia Notch is owned by the State of New Hampshire where the WMNF Forest Supervisor has no jurisdiction. If the State of New Hampshire believes that it is inappropriate to use the Franconia Notch Parkway for co‐locating a high voltage transmission line, then it should say so. <br />
<br />
The draft ROD states that “both the FHWA and NH DOT have expressed safety and traffic concerns with this [I‐93] potential route.” The draft ROD provides no evidence of such claims. If there are written communications to WMNF or DOE from FHWA and/or NH DOT making such claims they should be referenced. If there are no such communications this language should be deleted from the ROD. <br />
<br />
In June 2016 the Governor of New Hampshire signed into law House Bill 626 (copy attached). This law establishes energy transmission corridors in each of four highway rights of way owned in fee by the State of New Hampshire (Interstate 93, Interstate 95, Interstate 89 and Route 101 between Manchester and I‐95). In addition, this law instructs the NH DOT to update its Utility Accommodation Manual (note highlights) to streamline the process for making these facilities accessible to utility projects. The WMNF Supervisor goes to great lengths in the draft ROD to explain why alternatives “utilizing I‐93 are not consistent with my understanding of NH DOT policies.” But there is no mention of HB 626 or the re‐write of the Utility Accommodation Manual to accommodate the use of I‐93 for project like Northern Pass. <br />
<br />
REMEDY: The final ROD should remove all references to the suitability of Interstate‐93 through Franconia Notch State Park as an inappropriate location for the Northern Pass project because 1) this is not the jurisdiction of the US Forest Service and 2) the State has adopted a new law that actually encourages I‐93 to be considered by energy developers as an appropriate corridor for the location of a project like Northern Pass. The Forest Supervisor is certainly entitled to opine that he would prefer to have a project like Northern Pass disrupt 10 miles of roads on Forest Service land (as is the case with his preferred alternatives) rather than have the project only disturb 1.7 miles of Forest Service land (as would be the case if NP were to be buried within I‐93 instead of Routes 18, 116 and 112). However, the draft ROD should limit its recommendations to land owned by the US Forest Service and leave siting recommendations on all other lands in the state to the NH Site Evaluation Committee. <br />
<br />
3. Faulty Public Interest Determination <br />
<br />
Reason for Objection: The draft ROD Public Interest Determination (Section 1.4.2.1) suffers from three major errors. <br />
<br />
The statement that “there is not currently any broad energy transmission routing policy at the federal or state level that evaluates energy transmission on a broader geographic scale” is only half true. It is accurate that there is no federal policy. As cited above, the State of NH adopted such a policy in 2016 with enactment of HB 626. <br />
<br />
Conclusions that the power from Quebec is low‐carbon and low cost, and that it will diversify the electricity supply in New England, are not supported by presentation of facts that support such claims. <br />
<br />
The public interest determination totally ignores the strong public opposition that has bedeviled Northern Pass since it was first introduced to New Hampshire in October 2010. It is hard to imagine how any discussion of “public interest” and Northern Pass could exclude such broad and strong public sentiments. We agree with the WMNF Supervisor that a buried line through the White Mountain National Forest is preferable to an overhead line. We believe the Supervisor’s initial efforts to have the EIS review buried options are commendable. However, we believe the Supervisor failed to fully address the question as to whether this proposed use of WMNF land is in the public interest. The draft ROD Public Interest Determination concludes that the project “will benefit the public by providing low‐carbon, cost‐effective and diversified source of electricity for the people of New Hampshire and New England.” <br />
<br />
The claim that the project is “low carbon” may be accurate if the comparison is to coal or some other fossil fuel. However, carbon is not the only greenhouse gas, and there has never been a full greenhouse gas accounting for this project over its 40 year life cycle, listing all credit and all debits, and properly accounting for the time over which they accrue. The draft ROD should recognize this fact. The claim that this project is “cost effective” is not borne out by the facts. If NECPL can build an extension cord from Quebec to New England for $1.2 billion, and NP can build an extension cord for $1.6 billion, and the price of the Quebec power is the same regardless of which line carries the electrons, how is NP “cost effective”? The draft ROD should explain what it means by “cost‐effective.” </div>
<div>
</div>
<div>
Hydro power may diversify the portfolio of New England electricity generation, but price is what drives the wholesale power market in New England. If a particular source of electricity generation cannot compete on price, it does not succeed in the ISO‐NE managed wholesale market. By ignoring this essential element of how electricity is sold at the wholesale level in New England, the draft ROD concludes that the power from Quebec will actually be competitive without any consideration or analysis of how natural gas prices are currently driving the New England electricity markets. <br />
<br />
Northern Pass and the FEIS both argue that the carbon and cost benefits of Northern Pass as proposed are reasons for advancing the project. The New Hampshire Site Evaluation Committee has received considerable evidence calling these claims into question. Before issuing a final ROD the WMNF Supervisor should review the NH SEC record on these issues and use this review to reconsider claims made in the draft ROD. <br />
<br />
Another shortcoming of the public interest determination in the draft ROD is the absence of any discussion about the public opposition to the project. It says nothing about how the people and communities most directly impacted by Northern Pass strongly oppose the project as proposed. It says nothing about the substantive concerns that led thousands of people to attend public scoping sessions and hearings on the EIS and to provide public comments. <br />
<br />
It says nothing about the fact that 26 of the 31 affected communities overwhelmingly passed resolutions at town meetings opposing Northern Pass. Given the decades of emphasis that the WMNF has placed on building strong community and partner relationships, it is really quite astonishing that this 17 page draft ROD is totally silent on the public interest as the public sees it. <br />
<br />
REMEDY: Remand the draft ROD to the WMNF Supervisor to reconsider the conclusion that low‐carbon, low‐cost and diversification of supply issues are thoroughly and properly assessed. In addition, the final ROD should include consideration of the strong public opposition to Northern Pass in the ROD’s Public Interest Determination.<br />
<br />
We believe this draft ROD needs considerably more work before it is finalized. We strongly encourage the Regional Forester to remand the draft decision to the WMNF Supervisor for further consideration for the reasons cited above. The WMNF, the “land of many uses,” is a public asset. We should all think long and hard before we encourage these lands to be used to host and enable such an enterprise. <br />
<br />
Sincerely, <br />
<br />
Jane A. Difley, </div>
<div>
President/Forester <br />
<br />
cc: Clare R. Mendelsohn, Forest Supervisor, WMNF <br />
Enclosure: New Hampshire House Bill 626, Introduced 2015, Enacted 2016 </div>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-22401558735846073942017-10-13T17:47:00.000-07:002017-10-14T12:48:08.215-07:00AMC's Objection to WMNF's Draft ROD (Oct. 13, 2017)<div style="text-align: center;">
<b>Appalachian Mountain Club's Objection to the WMNF's </b><br />
<b>"Draft Record of Decision" </b><b>on Northern Pass</b><br />
<b><br /></b>
<b>(Read SPNHF's objection <a href="http://burynorthernpass.blogspot.com/2017/10/spnhfs-objection-to-draft-rod-oct-13.html">here</a>.)</b><br />
<b><br /></b>
<b>(Read CLF's objection <a href="http://burynorthernpass.blogspot.com/2017/10/clfs-objection-to-wmnfs-draft-rod-oct.html">here</a>.)</b></div>
<br />
Mary Beth Borst, Reviewing Officer<br />
USDA Forest Service, Eastern Region<br />
626 East Wisconsin Avenue, Suite 700<br />
Milwaukee, WI 53202<br />
(414) 944-3963 (FAX)<br />
objections-eastern-region@fs.fed.us<br />
<br />
October 13, 2017<br />
<br />
RE: Objections of the Appalachian Mountain Club to the ‘Draft Record of Decision - Final
Northern Pass Transmission Line Project Environmental Impact Statement, White
Mountain National Forest, Grafton County, New Hampshire’<br />
<br />
Dear Ms. Borst:<br />
<br />
Thank you for this opportunity to provide our objections to the draft Record of Decision,
Environmental Impact Statement (EIS) for the Northern Pass Transmission project in the White
Mountain National Forest, NH. Founded in 1876, the Appalachian Mountain Club (AMC) is the
nation’s oldest conservation and recreation organization, with more than 100,000 members,
supporters, and advocates. Our mission is to promote the protection, enjoyment, and
understanding of the mountains, forests, waters, and trails of the Northeast and Mid-Atlantic
regions. The AMC is an intervener in the above‐referenced docket, and its standing in this case
was described in our motion to intervene of Dec. 15, 2010, and our April 4th, 2016 comments on
the US Department of Energy Draft EIS and Supplement (DEIS), which included objections
based on timely and specific written comments regarding the proposed project. AMC raises the
following objections to the draft White Mountain National Forest (WMNF) EIS Record of
Decision (draft ROD) without prejudice to any and all legal rights AMC may have, which are
hereby expressly reserved.<br />
<br />
On April 4th 2016 AMC provided extensive comments on the DEIS and Supplement, and we are
disappointed to note that so little of what we suggested for improvement has been adopted in
either the US DOE FEIS or the draft ROD. Given the detail we previously provided about our
concerns, we will not repeat all of our argument here, but instead will highlight those areas
where we believe the draft ROD remains sorely lacking despite our previous comments and
recommendations, and based on new information arising after the designated comment
opportunities.<br />
<br />
Sections in the WMNF draft ROD relevant to AMC’s comments on the DEIS and FEIS<br />
<br />
Section 1.3 Purpose and Need<br />
<br />
The “Purpose and Need” defined by the DOE and adopted by Supervisor Wagner is unduly
narrow, and precludes full consideration of the “public interest” which should be at the heart of
the WMNF analysis. As AMC noted in its DEIS and FEIS comments:
“The purpose of, and need for, the DOE’s action is to determine whether or not to grant the
requested Presidential permit for the Project at the international border crossing proposed in the
amended Presidential permit application (Northern Pass 2015).”<br />
<br />
The statement of the agency’s underlying “purpose and need” in an EIS is critical to identifying
the range of reasonable alternatives. Obviously, if the “purpose and need” is defined too broadly,
the number of alternatives requiring analysis would be virtually limitless. Conversely, it is
inappropriate to define “purpose and need” so narrowly that only a single alternative with
variants could be identified for realistic and fair analysis (as is the case in this Application). As
recognized in DOE’s Recommendations for the Preparation of Environmental Assessments and
Environmental Impact Statements, (Second Ed., Dec. 2004 at page 5), “The proposed action is
generally only one means of meeting the agency’s underlying purpose and need for action.”<br />
<br />
The FEIS, as in the DEIS, incorrectly applies a narrow interpretation based on 10 CFR part 250.
A purpose and need statement cannot lawfully be premised on the narrow objective of
determining whether or not to grant a permit for a particular proposal. Indeed, as written, DOE’s
purpose and need statement allows for just one alternative to the approval of the Applicant’s
proposal: denial of the project as proposed.<br />
<br />
Section 1.4.2 Decision Rationale<br />
<br />
The Forest Supervisor’s rationale includes “the benefit from the engagement and valuable input
from participating state and federal agencies, particularly, the EPA – Region 1, the USACE –
New England District, and the NHOEP, who participated as cooperating agencies.” Ironically,
the U.S. Environmental Protection Agency-Region 1 (EPA), in a letter dated September 26, 2017
to the USACE-New England District (attached as Appendix 1), reiterates its position that a
hybrid Alternative 7, which includes the burial of an additional 40 miles to protect wetlands,
needs further analysis. This alternative would also eliminate above ground transmission line
segment impacts to the White Mountain National Forest (WMNF).<br />
<br />
The Forest Supervisor’s
rationale is premature considering this filing by the very agency he cites as crucial to the EIS
process.
The Forest Supervisor’s rationale also includes: “In addition, the alternatives utilizing I-93 are
not consistent with my understanding of NHDOT policies. The 2010 NHDOT Utility
Accommodations Manual stipulates that “Longitudinal installations [utility lines] are not
permitted within the LAROW [Limited Access ROW, i.e., I-93]” unless the Applicant is capable
of demonstrating that “an extreme hardship” would be imposed on the Applicant, and that
“alternate locations are not available.” Because the Applicant has proposed the Project
configuration as detailed in Alternative 7, which proposes the transmission line to be buried
along NH Routes 112 and 116, the Applicant could not demonstrate that “alternate locations are
not available,” and/or that “an extreme hardship” would be imposed.” But in contradiction to
the Supervisor’s stated rationale, Northern Pass (the Applicant), in its Application before the NH
Site Evaluation Committee (SEC), and as reviewed in the US DOE DEIS and FEIS, bases its
Preferred Alternative on the assumption that the Project would indeed for the most part be buried
under NH Routes 112 and 116, not beside the roadway1
, and therefore would have only short
term impacts2
.<br />
<br />
The DEIS and FEIS appear to be based on the premise that the 60 miles of buried transmission
line is practical and can be buried under the road pavement, as the Applicant originally proposed,
but has since backed away from. During the NH Site Evaluation Committee adjudicatory hearing
session on September 14th, 2017, the Grafton County Commissioners put into the record that the
NH Department of Transportation (DOT) policy in fact prohibits burial under the pavement.
Rather, burial needs to occur in the adjacent ROW. As a result, the Applicant is now trying to
engineer a project that will actually fit into the NH DOT ROW outside of the roadway, and to
receive permission from DOT for such construction. But the incomplete and in many instances
erroneous information provided by the Applicant thus far has delayed any true understanding of
what burial in the ROW would actually involve, including on what side of the road, and what
resources would be impacted. Yet the DEIS, FEIS, and draft ROD all assume the proposed burial
route is practical based on burial under the roadway, and based on that premise determine that
the impacts would be short term. But that premise is no longer valid.<br />
<br />
Clearly the FEIS and draft
ROD are premature.
It is also ironic that the Applicant made a strong case, which the DEIS, FEIS, and draft ROD
adopt, that burial under I-93 through Franconia Notch and south to the target Massachusetts
power market would not be permissible due to the ‘2010 NHDOT Utility Accommodations
Manual’ preventing under-pavement burial. Yet the Applicant has proposed burial under the
pavement of state roads, and this was assumed practical in the DEIS, FEIS and draft ROD, but
has now been recently denied by the NH DOT as explained above.<br />
<br />
Finally, we will note that the idea of burying the line under the Franconia Notch bikeway as an
alternative to burial under I-93 itself was never analyzed as an option for addressing the
constraints in Franconia Notch State Park.<br />
<br />
[ 1
The FEIS at page 2-44 assumes the burial will primarily be under the roadway , i.e. “Short-term disturbance for the
trench and construction activities is assumed to be 10 feet (3 m) wide, with the majority of disturbance limited
to the road surface (approximately 30 feet [9 m] wide) and adjacent, previously disturbed areas.” NH DOT has
determined that burial under the roadway is contrary to their policy and burial would need to take place outside of
the road surface.
2
The FEIS at page 2-44 assumes the burial will primarily be under the roadway , i.e. “Short-term disturbance for the
trench and construction activities is assumed to be 10 feet (3 m) wide, with the majority of disturbance limited
to the road surface (approximately 30 feet [9 m] wide) and adjacent, previously disturbed areas.”]<br />
<br />
1.4.2.1 Public Interest Determination<br />
<br />
The Forest Supervisor states, “In contemplating authorization of the Project, I have considered
whether the Project is in the public interest. In addition to the Decision Rationale detailed
herein, I believe that the Project will benefit the public by providing a low-carbon, cost-effective,
and diversified source of electricity for the people of New Hampshire and New England.”
However, it has been raised but not thoroughly vetted or verified in either the FEIS or draft
ROD, that moving Hydro-Quebec power into the New England market to capture higher prices
resulting from the MA Clean Energy 83D Request for Proposal (should Northern Pass win that
bid), would actually just be diverting that same power from its current use in New York and
Ontario. If that is the case, the question arises as to what would replace the Hydro-Quebec
power in New York and Ontario. A recent report states that if the replacement power in those
markets is in part or in whole natural gas, then reducing GHG emissions in the New England
market at the expense of neighboring states and provinces would result in no to minimal overall
GHG benefit3
. The Forest Supervisor did not analyze that possibility, and likely lacks the
expertise to make that judgment.<br />
<br />
The Forest Supervisor states “Consistent with manual guidance for SUPs, I have considered
whether this project could be reasonably accommodated on non-NFS lands.” He concludes no.
Yet there are 46 proposals in the MA Clean Energy 83D Request for Proposal (MA Clean
Energy RFP), 44 competing with Northern Pass, and many on non-federal lands. In fact, the
DEIS and FEIS determine that the existing HVDC line in NH is not a feasible alternative and
therefore it was not studied further. But in July 2017, GridAmerica Holdings, a subsidiary of
National Grid and the owner of that transmission line, has since developed and submitted a bid
into the MA Clean Energy RFP that uses that existing HVDC corridor in NH by upgrading the
existing lines to carry the same amount of power as Northern Pass 4
.<br />
<br />
In addition, the issue of energy diversity cited by the Supervisor lacks sufficient analysis. As
AMC points out in its DEIS comments of April 2016: “The rationale given for this proposed
project is in part to promote electricity diversity due to the rapid transition to dependence on
natural gas power generation. Hydro-Quebec currently has an export capacity into New England
of approximately 2,275 MW and the DEIS projects that this project would increase it by another
31+% . Should the Northern Pass (1,090 MW), the New England Clean Power Link (1,000
MW), and Vermont Green Power Line (400 MW) transmission projects all come to fruition, this
would increase the region’s dependency on Hydro-Quebec to over 4,760 MW of capacity. This
excludes additional imports from other Canadian provinces. New England-ISO currently has ca.
31,000 MW of capacity, therefore if Hydro-Quebec were to backfill for generation being retired,
it has the potential to become a dominant source of the New England-ISO generation capacity.
In 2015 Canadian hydropower was approximately 13% of the region’s net electric energy load,
and the DEIS estimates that Northern Pass would increase this by 31%. Based on the New
England-ISO consumption of 126,874 gigawatt-hours (GWh) in 2015 and an 80% capacity-use
factor for all proposed Hydro-Quebec transmission lines, Hydro-Quebec could approach one
quarter of the region’s power generation consumed (GWh). The DEIS at Section 2.5.2 suggests
ca. 20%, but that calculation needs to be updated as it appears to not include additional Hydro- [3 http://indepthnh.org/2017/09/21/study-granite-state-power-link-bests-northern-pass-on-co2-reductions/
4 https://macleanenergy.com/83d/83d-bids/]<br />
<br />
Quebec generation separately bid into the CT/MA/RI RFP (Vermont Green Power Link), or
recently permitted transmission (e.g. NECPL) designed to host Hydro-Quebec generation. And
this excludes other Hydro-Quebec exports to the US from its subsidiaries in New Brunswick and
Newfoundland/Labrador. In summary a continued transition to Hydro-Quebec generation will
shift today’s dependency on natural gas towards a dependency on Hydro-Quebec, a shifting of
the electrical diversity problem but not necessarily the solving of it (emphasis added). It would
put the region’s grid and markets at risk with this increased reliance on power from a sole source
provider, a dependency on a few multi-thousand mile long transmission lines which have
historically suffered major disruptions about every decade, and the likelihood that if an energy
shortage occurred, Quebec’s internal power needs would trump those of New England given that
Hydro-Quebec is owned by the Province of Quebec. And like California hydropower this past
drought year, future Canadian hydro power generation during the tenure of the Northern Pass
project could become less certain due to climatic changes in temperature and precipitation.”<br />
<br />
In summary Supervisor Wagner takes at face value the assertions about regional energy needs
and diversity concerns that are contradicted by both information placed in the record but not
considered by DOE, and new information. That energy policy is not a matter in which
Supervisor Wagner has expertise only underscores that his reliance on these issues for his draft
ROD decision is flawed.<br />
<br />
Sincerely,<br />
<br />
Susan Arnold<br />
Vice President for Conservation<br />
Appalachian Mountain Club<br />
<br />
Cc: Stacy Lemieux, Project Leader WMNF slemieux@fs.fed.us<br />
Clare R. Mendelsohn, Forest Supervisor WMNF clarermendelsohn@fs.fed.usUnknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-36794712442500744512017-08-23T05:15:00.003-07:002017-08-23T08:19:54.107-07:00 The Battle Of Northern Pass: NHSEC Asked To Suspend Proceedings Over Inaccuracies In Plans<b><br />The Battle Of Northern Pass: NHSEC Asked To Suspend Proceedings Over Inaccuracies In Plans</b><br />
<b><br />NHDOT Rejects Northern Pass ROW Survey*</b><br />
<br />
Robert Blechl<br />
Caledonian Record<br />
August 23, 2017<br />
<br />
The Grafton County Commission is asking the N.H. Site Evaluation Committee to suspend its Northern Pass proceedings until the company submits accurate plans and resolves uncertainty about rights-of-way for the burial of lines under state highways.<br />
<br />
At the same time, the N.H. Department of Transportation has rejected survey reports prepared by Northern Pass contractors requiring certification that the right-of-way (ROW) lines shown on the plans are accurate locations defined by ground survey and research.<br />
<br />
“As stated … from the Bureau of Right of Way, neither of the reports submitted have met that requirement,” NHDOT engineer Melodie Esterberg wrote Northern Pass on Aug. 11. “It is critical that the ROW information on the plans is accurate as this is the basis for the Department to evaluate the proposed alignment of the [Northern Pass line] as it relates to the Department’s infrastructure.”<br />
<br />
Additionally, in what is increasingly shaping to be a potential legal challenge, a growing number of towns are voicing concerns about Northern Pass claiming the right-of-way (ROW) width it needs to install underground transmission line could extend to and impact private property along the roads.<br />
<br />
“For the accuracy of the plans to still be questioned by none less than the Department of Transportation after the construction panel has allegedly finished testimony is stunning,” Grafton County Attorney Lara Saffo, representing the GCC, wrote to the NHSEC.<br />
<br />
In a 41-page motion with exhibits, Saffo said Northern Pass has submitted what appears to be more than 100 exception requests for its project, each significant and including exceptions pertaining to ROWs.<br />
<br />
“The July 18, 2017 minutes, posted on Aug. 2, 2017, reflect DOT concerns about the accuracy of the diagrams provided by Northern Pass,” she wrote the NHSEC.<br />
<br />
Quoting the meeting minutes, Saffo said, “Esterberg noted that these errors make Department personnel wonder about the accuracy of existing facilities and the right-of-way. Maintenance and Design Services personnel have been told to make NPT review a priority, but errors and inaccuracies are making the review take longer and diverting resources from personnel’s normal job responsibilities hinders highway maintenance and project development activities.”<br />
<br />
She also asks the NHSEC to recall the construction panel to address the viability of the exception requests.<br />
<br />
“[Northern Pass] cannot complain that deadlines are not being met when [it] continues to change the design of the project, adds exception requests and submits plans that have inaccuracies, necessitating DOT to now question ‘the accuracy of existing facilities and the right-of-way throughout the entire route,’” said Saffo.<br />
<br />
In an objection to the GCC’s request to suspend NHSEC hearings, Northern Pass attorney Thomas Getz said the county commission’s pleading is without merit because it “continues to misapprehend the permitting role of the DOT in the SEC process” and the DOT process has been developed in a way that allows an applicant to refine its design over time and conform it to DOT’s specific requests.<br />
<br />
But those changes are not sitting well with local towns.<br />
<br />
On July 17 and July 31, respectively, the towns of Easton and Franconia wrote NHDOT Commissioner Victoria Sheehan, requesting she enact RSA 228:35, the statute on the reestablishment of highway boundaries.<br />
<br />
On Monday, Bethlehem joined the two towns in petitioning Sheehan to enact the RSA to reestablish lost or uncertain ROWs along the North Country state roads that would be impacted. The line is proposed for burial under Routes 302 and 116 in Bethlehem and Routes 116 and 18 in Franconia and Easton.<br />
<br />
In the Bethlehem letter, concerns were expressed that underground transmission line infrastructure could involve removing stone walls, trees, lawns, fences and gardens that private property owners believe are outside the ROW.<br />
<br />
The ROWs aren’t clearly established and there are undetermined widths, Cheryl Jensen, chair of the Bethlehem Conservation Commission and the town’s liaison for Northern Pass matters, said to selectmen Monday.<br />
<br />
“Property owners don’t understand the ramifications this could have on their properties,” she said.<br />
<br />
In an Aug. 8 response to the town of Easton, Sheehan said the formal reestablishment of the ROW through RSA 228:35 is typically only considered when, after thorough investigation, the location of the ROW is not defined or there are questions about it.<br />
<br />
NHDOT is currently requiring Northern Pass to complete a survey report that will document and define the types of ROW on the segments where the project would be within state roads, she said.<br />
<br />
“The survey report must compile this information and be completed to the DOT’s satisfaction,” wrote Sheehan. “Northern Pass has not provided this information in a satisfactory format at this time.”<br />
<br />
__________________________<br />
<br />
NHDOT's rejection of NPT's right-of-way survey (8/11/2017) is <a href="https://www.nh.gov/dot/media/northern-pass/documents/dot-survey-report-response-lot.pdf">here.</a> The DOT's overall page on Northern Pass, including NPT's 122 requests for exceptions to DOT's rules, is <a href="https://www.nh.gov/dot/media/northern-pass/index.htm#survey">here.</a>Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-86034466986166312172017-07-29T06:53:00.001-07:002017-07-29T07:48:22.055-07:00SEC Site Visit to Franconia: Disappointing (7/28/2017)<br />
Franconia Site Visit: NHSEC Arrives Early, Disappoints Northern Pass Opponents<br />
<br />
NHSEC Wraps Up Two Days Of North Country Site Visits Friday<br />
<br />
Robert Blechl <br />
<div>
Caledonian Record </div>
<div>
July 29, 2017<br />
<br />
<br />
<img height="265" src="https://bloximages.newyork1.vip.townnews.com/caledonianrecord.com/content/tncms/assets/v3/editorial/d/0d/d0de97a5-d4ab-5cf8-be48-a58433ce9011/597bb45e2ab83.image.jpg" width="400" /><br />
<br />
<span style="font-size: x-small;">Hoping to make a statement to the committee that will decide if Northern Pass will be approved, dozens of orange-clad opponents were disappointed Friday after members of the N.H. Site Evaluation Committee made their site visit more than an hour earlier than scheduled. (Photo by Robert Blechl)</span><br />
<br />
<a href="https://www.facebook.com/sharer/sharer.php?u=http%3A%2F%2Fwww.caledonianrecord.com%2Fnews%2Flocal%2Ffranconia-site-visist-nhsec-arrives-early-disappoints-northern-pass-opponents%2Farticle_c8ff8346-fe6d-5abf-89f6-f67b49516a21.html%3Futm_medium%3Dsocial%26utm_source%3Dfacebook%26utm_campaign%3Duser-share"></a><br />
FRANCONIA — Seeing it as an opportunity when they could almost be face to face, opponents of Northern Pass were hoping to make a statement to members of the N.H. Site Evaluation Committee, which made a site visit Friday afternoon.<br />
<br />
Instead, NHSEC members arrived more than an hour before their scheduled visit in Franconia and were gone after about 10 minutes, before virtually all of the several dozen opponents, wearing orange and some holding “No To Northern Pass” signs, arrived.<br />
<br />
“We were going to be polite,” said Lisa Cutler, of Easton, who, with her husband, Ned, chair of the Easton selectboard, arrived a half hour before the estimated 2:15 p.m. visit by the NHSEC.<br />
<br />
<div>
The committee is visiting portions along the Northern Pass route to study the impact the proposed transmission line would have.<br />
<br />
As project opponents trickled into downtown, they were disappointed to learn of the early arrival. Some voiced suspicions it was a deliberate attempt by the NHSEC to avoid area residents turning out in Franconia, which has been a hotbed of Northern Pass opposition.<br />
<br />
“To me, this is a public process and the public should see what they’re doing,” said Nancy Martland, of Sugar Hill.<br />
<br />
The NHSEC should have visited to see not only what would physically be impacted by the project, but to see the people who would be impacted, said Kevin Johnson, owner of the Gale River Motel in Franconia.<br />
<br />
“They avoided it by getting here an hour earlier,” he said. “It makes me question the objectivity of the committee and if they are interested in really weighing the pros and cons … People took time out of their day to come here.”<br />
<br />
Two of them were Bob Sherburn and his daughter, Alyssa Sherburn, who run the Pinestead Farm Lodge, in Franconia, which has been in the family for generations.<br />
<br />
“This is unfair,” said Bob Sherburn.<br />
<br />
The Northern Pass line would run under Route 116, right in front of the main Pinestead farmhouse that regularly welcomes guests, said Alyssa Sherburn.<br />
<br />
“This would really disrupt business,” he said.<br />
<br />
Opponents favor burial, but many want a fully buried line, along Interstate 93, and not through downtown Franconia and Easton, where they say businesses would be hurt through two seasons of construction and ripped up roads, which they contend would also negatively impact residential properties.<br />
<br />
The NHSEC is the entity that will decide whether or not to issue Northern Pass a certificate of site and facility, which is needed for the estimated $1.6 billion, 1,090-megawatt-capacity, 192-mile transmission line to advance. The NHSEC could make its decision later this year.<br />
<br />
As proposed, the line would be all overhead except for 7 1/2 miles of underground line in Coos County and 52 miles underground from Bethlehem to Bridgewater.<br />
<br />
Because they were on the road Friday, NHSEC administrator Pam Monroe and committee members were unavailable for comment and it was undetermined why the committee showed up more than an hour before their scheduled time in Franconia.</div>
<div>
On Thursday, NHSEC members arrived in Coos County for site visits in upper Coos that included Pittsburg, where the line would cross the international border, and Clarksville.<br />
<br />
On Friday, after visiting Stark and Weeks State Park in Lancaster, which would have views of overhead towers, they visited Bethlehem and Franconia, which, along with Easton and Sugar Hill, would have buried line along state highways.<br />
<br />
According Kenneth Bowes, engineer for Eversource Energy, the parent company of Northern Pass, the traffic control at Routes 18 and 116, where the line would make a sharp right and cross under the Gale River, “is probably the more complicated of any of the locations along the route …”<br />
<br />
At the moment, the big legal challenge that appears to be shaping up against Northern Pass in the North Country is the project’s use of local roads.<br />
<br />
Last week, the Easton Board of Selectmen wrote Victoria Sheehan, commissioner of the N.H. Department of Transportation, to request that the NHDOT enforce N.H. RSA 228:25, the statute on the reestablishment of highway boundaries.<br />
<br />
The RSA states whenever it is the opinion of the NHDOT commissioner that the boundary lines, limits, or locations of any highways become lost, uncertain, or doubtful, the commissioner can reestablish them the same as they were originally established.<br />
<br />
“At issue here is a private project proposing to use public roads for a highly invasive project,” the Easton selectmen said to Sheehan. “Its size and length are unprecedented in New Hampshire and the majority of road abutters do not know what the road width is, and therefore are unable to defend their property rights, when they even know that there is an issue of unknown width.”<br />
<br />
The Easton board members said many people assume that when the state took over the roads, it set a standard right-of-way width, but that is untrue.<br />
<br />
“Abutters and travelers have a right to a clear determination of road widths, yet what is being proposed is a permit of a project which has not provided adequate proof of ROW widths,” wrote the selectmen. “Even with all the relevant information in hand, some roads on the proposed route were laid out without the width of the road being specified, so there is inescapable uncertainty about the road boundaries.”<br />
<br />
<div style="text-align: center;">
###</div>
<div style="text-align: center;">
<b><i><br /></i></b></div>
<div style="text-align: left;">
<b><i>See the companion piece to this post <a href="http://burynorthernpass.blogspot.com/2017/07/route-116-franconia-easton-says-no-to.html">here.</a></i></b></div>
</div>
</div>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-16634143903225310152017-07-28T14:38:00.000-07:002017-07-29T07:46:09.134-07:00Route 116 (Franconia - Easton) Says NO to Northern Pass (7/28/2017)<div style="text-align: center;">
<span style="font-size: large;">Route 116 (Franconia - Easton) Says NO to Northern Pass</span></div>
<div style="text-align: center;">
<br /></div>
<div style="text-align: center;">
Site Evaluation Committee Site Visit, July 28, 2017</div>
<div style="text-align: center;">
<br /></div>
<div style="text-align: center;">
<br /></div>
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<b>Read the companion piece to this post <a href="http://burynorthernpass.blogspot.com/2017/07/franconia-site-visit-nhsec-arrives.html">here.</a></b></div>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-19750118751505796292017-07-23T08:08:00.000-07:002017-07-23T09:34:10.049-07:00Franconia area residents take local concerns about Northern Pass to Concord (July 20, 2017)<br />
<span style="font-size: large;"><b><br />Franconia area residents take local concerns about Northern Pass to Concord</b></span><br />
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<b>SEC Public Statement Hearing, Concord, July 20, 2017</b><br />
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<tr><td class="tr-caption" style="text-align: center;">Patricia Kellogg displays "New Hampshire's Heritage" at the<br />
SEC Public Hearing in Concord, July 20, 2017</td></tr>
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Along with over thirty other New Hampshire citizens and a delegation from the Pessamit Innu First Nation in Quebec, six Franconia area residents traveled to Concord on July 20 to voice their concerns about the proposed Northern Pass project to the Site Evaluation Committee, which is currently deciding whether or not to permit the 192-mile transmission line. This was the third hearing held in the last month for non-intervenors to state their views to the SEC. <br />
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Grouped into two parties, two dozen residents of Bethlehem, Franconia, Easton, and Plymouth who live along the proposed underground route were granted pro se intervenor status in 2016, and representatives of these two groups have been participating in the adjudicative process for the last 18 months. In the White Mountains area, the towns of Littleton, Bethlehem, Franconia, Sugar Hill, Easton, Plymouth, and Ashland have retained counsel to represent them as intervenors, with County Attorney Lara Saffo representing the Grafton County Commissioners.<br />
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SEC Chair Martin Honigberg noted that the July 20th session was the sixteenth public hearing that the SEC has held on this project and that the nearly 1900 written comments submitted to date and posted on the SEC’s website are running 12 to 1 against the project as proposed. <br />
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In the July 20th hearing, Franconia area speakers stressed heritage – both what we have inherited and what we must strive to pass on to future generations. As a third generation family owner of Polly’s Pancake Parlor, which opened in 1938, Katherine Aldrich Cote remarked that the Franconia area has been known as “a destination for tourists escaping the heat, noise, and traffic of cities since the late 1800’s.” She noted that Polly’s has kept meticulous attendance records and knows how past road construction and other events along Route 18/116 in Franconia, the proposed site of the construction project to install the Northern Pass cable, have negatively affected business. Over two-thirds of Polly’s guests travel that route to reach Sugar Hill. Project sponsors estimate a minimum of two construction years – April to November – to install the underground cable, which, Cote said, collides with the annual peak period of Polly’s visitors. In 2016, Polly’s served 71, 031 of its 93, 500 customers between April and October. <br />
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Cote presented the SEC with 75 letters voicing similar concerns about the impacts of underground construction on Franconia area businesses and implored the committee “to consider the negative long-term effects of this project on our small towns and businesses. Tourist will avoid the area, find other destinations to visit, and may not return for many years, if at all.”<br />
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Patricia Kellogg, Littleton, displayed a large photo entitled “New Hampshire’s Heritage.” It reproduces a well-known nineteenth century painting of Franconia Notch on which her husband, a licensed surveyor, has drawn in a simulation of Northern Pass’s towers and wires to underscore the point that tourists do not visit the Franconia area to experience major infrastructure projects. She also implored the SEC to preserve “the New Hampshire advantage,” our pristine scenic heritage, for future generations to enjoy.<br />
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Dorothy McPhaul, Sugar Hill, and Brenda Shannon Adam, Easton, coordinated their statements to contrast the proposed underground routes of Northern Pass and of a rival project in Vermont, the New England Clean Power Link, which is now fully permitted. McPhaul drove the 57-mile overland portion of the NECPL route from Benson to Ludlow, Vt. on July 10 and observed that the differences between it and Northern Pass’s underground plans are “stunning.” The Vermont project, sited on four-lane highways and back roads that two towns have approved, will bypass all municipal centers, allowing them to continue business as usual. “NECPL is done with intensive planning by experts who care about the people as well as the finished product,” McPhaul said. “Northern Pass is a jumbled up mess of partially thought out plans, partially conducted studies, outdated maps and data, a staff of puppets, a reliance on its attorneys and contacts to make exceptions, grant waivers, ignore deficiencies, fool the public, lie if need be, and with plans ‘made as you go’ without sufficient knowledge and research,” she charged. <br />
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Adam drove Northern Pass’s proposed 52-mile underground route from Bethlehem to Bridgewater on July 2, the day after flash flooding swept through Grafton County, wondering “if the narrow ancient corduroy roads would disintegrate and swallow me up in an underground river like the videos I watched of 25A in nearby Orford.” How will these fragile roads hold up, she asked the SEC, when Northern Pass increases the traffic by 120% with heavy construction vehicles? As a further insult, Adam remarked, “the route cuts through the heart of three significant economic centers - Franconia, North Woodstock, Plymouth.”<br />
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Susan Ford, Easton, reminded the SEC that small towns in the North Country’s mountainous terrain have a limited number of roads. Downtown Concord was recently torn up for two years during a construction project to enhance the business district, but Ford knew she could avoid Main Street construction by traveling on Storrs Street, State Street or Green Street, and she could walk on sidewalks to Main Street businesses. “There is only one almost parallel road to Rt. 116 in Franconia and that’s five miles away. We can’t go around the block – there are no blocks,” Ford said. As a former Representative, Ford also reminded the SEC that the New Hampshire Legislature has reconfigured the siting process to include a “public interest” standard. The public interest is best served, Ford concluded, by moving the Northern Pass project to I-93. <br />
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The protracted length of the project and the intense opposition it has generated since 2010 were underscored by Melissa Elander, also of Easton. She presented the SEC with six cartons holding 20,000 petitions – “20, 000 voices” - opposing the project, 5,000 of which are directly addressed to the SEC and urge burial on I-93. <br />
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You may still sign the Change.org petition to the SEC; go to the website and search for “Northern Pass.” The SEC also continues to accept written public comments, which should be addressed and emailed to Pamela G. Monroe, SEC Administrator at <a href="mailto:Pamela.Monroe@sec.nh.gov">Pamela.Monroe@sec.nh.gov</a>. Franconia area business owners who wish to add their letters to the existing group of 75 may send them to <a href="mailto:BuryNorthernPass@gmail.com">BuryNorthernPass@gmail.com</a>. Please address these letters to the SEC and they will be forwarded as part of the business group. <br />
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<tr><td style="text-align: center;"><a href="https://1.bp.blogspot.com/-dV32Z84Cy_s/WXTGsVAddsI/AAAAAAAAA5k/yljKd0GCEA81c8inJw1nb4MEjVKOZy4yQCLcBGAs/s1600/Elander.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="1600" data-original-width="799" height="400" src="https://1.bp.blogspot.com/-dV32Z84Cy_s/WXTGsVAddsI/AAAAAAAAA5k/yljKd0GCEA81c8inJw1nb4MEjVKOZy4yQCLcBGAs/s400/Elander.jpg" width="198" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;">Peter Martin rolls in boxes of petitions, signed by 20,000 opponents,<br />
that the Martins and Melissa Elander have collected since 2010.</td></tr>
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<br />
Susan Schibanoff<br />
EastonUnknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-16575593665558632212017-07-04T16:11:00.000-07:002017-07-05T07:04:56.508-07:00Routes 3, 18, and 112 Damaged by Flash Flooding, July 1, 2017<div style="text-align: center;">
(For photos of Easton's Route 116, click <a href="http://burynorthernpass.blogspot.com/2017/07/eastons-rte-116-damaged-by-flash.html">here.</a>)</div>
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<b><span style="font-size: large;">Severe Thunderstorm Warning, July 1, 2017</span></b></div>
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<tr><td style="text-align: center;"><a href="https://1.bp.blogspot.com/-Qa1v6F3hkNU/WVwf4PCABTI/AAAAAAAAA2k/RrsRW5sinhsETQZd0-RcPDy6BHAyOOvpACLcBGAs/s1600/7%2B1%2B17%2BTstorm.JPG" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="704" data-original-width="836" height="336" src="https://1.bp.blogspot.com/-Qa1v6F3hkNU/WVwf4PCABTI/AAAAAAAAA2k/RrsRW5sinhsETQZd0-RcPDy6BHAyOOvpACLcBGAs/s400/7%2B1%2B17%2BTstorm.JPG" width="400" /></a></td></tr>
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<b><span style="font-size: large;">The following photos of Routes 3 (Thornton), 18 (Sugar Hill), and 112 (Woodstock) </span></b><b><span style="font-size: large;">were taken on July 3-4, 2017</span></b></div>
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<tr><td style="text-align: center;"><a href="https://2.bp.blogspot.com/-TLiOgHy7Sw8/WVpcsaIM39I/AAAAAAAAA0c/IG4U3mnHNDEooXNCSWu_FJbcdf7vTTKKgCPcBGAYYCw/s1600/7_1_17%2Bbridgewater.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="640" data-original-width="480" height="400" src="https://2.bp.blogspot.com/-TLiOgHy7Sw8/WVpcsaIM39I/AAAAAAAAA0c/IG4U3mnHNDEooXNCSWu_FJbcdf7vTTKKgCPcBGAYYCw/s400/7_1_17%2Bbridgewater.jpg" width="300" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;">Rte. 3</td></tr>
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<tr><td style="text-align: center;"><a href="https://2.bp.blogspot.com/-hCrTa8TqqXA/WVpcKnRVHuI/AAAAAAAAA0Y/EvytVKFYrFUaR5DuRSymyStKpUi_eVj1QCPcBGAYYCw/s1600/7%2B3%2B17%2Bphoto.JPG" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="536" data-original-width="835" height="256" src="https://2.bp.blogspot.com/-hCrTa8TqqXA/WVpcKnRVHuI/AAAAAAAAA0Y/EvytVKFYrFUaR5DuRSymyStKpUi_eVj1QCPcBGAYYCw/s400/7%2B3%2B17%2Bphoto.JPG" width="400" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;">Rte. 3</td></tr>
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<tr><td style="text-align: center;"><a href="https://3.bp.blogspot.com/-9Nr4iqYVZe4/WVwYwqb3jsI/AAAAAAAAA2M/lFCdxTA45RY3LwLYLyDbl0NTrNColscZgCPcBGAYYCw/s1600/112%2B02%2BWoodsville.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="1176" data-original-width="1600" height="293" src="https://3.bp.blogspot.com/-9Nr4iqYVZe4/WVwYwqb3jsI/AAAAAAAAA2M/lFCdxTA45RY3LwLYLyDbl0NTrNColscZgCPcBGAYYCw/s400/112%2B02%2BWoodsville.jpg" width="400" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;">Rte. 112</td></tr>
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<tr><td style="text-align: center;"><a href="https://2.bp.blogspot.com/-TddhB5w10p8/WVwXxgS1PMI/AAAAAAAAA18/GQVVnDJqWKst6rUZcz3T192HJcPlmP50gCPcBGAYYCw/s1600/112%2B01%2BWoodstock.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="1294" data-original-width="1600" height="322" src="https://2.bp.blogspot.com/-TddhB5w10p8/WVwXxgS1PMI/AAAAAAAAA18/GQVVnDJqWKst6rUZcz3T192HJcPlmP50gCPcBGAYYCw/s400/112%2B01%2BWoodstock.jpg" width="400" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;">Rte. 112</td></tr>
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<tr><td style="text-align: center;"><a href="https://4.bp.blogspot.com/-bbiAfEMsv2c/WVzxv5LtgGI/AAAAAAAAA3I/OwbKcPaL1_EaeFwb8Oc0djJuSXrO9Z1oACLcBGAs/s1600/112%2B03%2BWoodstock.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="447" data-original-width="590" height="302" src="https://4.bp.blogspot.com/-bbiAfEMsv2c/WVzxv5LtgGI/AAAAAAAAA3I/OwbKcPaL1_EaeFwb8Oc0djJuSXrO9Z1oACLcBGAs/s400/112%2B03%2BWoodstock.jpg" width="400" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;">Rte. 112</td></tr>
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<tr><td style="text-align: center;"><a href="https://3.bp.blogspot.com/-B0emHddqyrk/WVwXAdhJkTI/AAAAAAAAA18/jsw6M8lViW0yJneN0J2u-qWhPyBtwIFKwCPcBGAYYCw/s1600/18%2B01%2BSugar%2BHill.JPG" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="691" data-original-width="400" height="400" src="https://3.bp.blogspot.com/-B0emHddqyrk/WVwXAdhJkTI/AAAAAAAAA18/jsw6M8lViW0yJneN0J2u-qWhPyBtwIFKwCPcBGAYYCw/s400/18%2B01%2BSugar%2BHill.JPG" width="231" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;">Rte. 18</td></tr>
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Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-57150869733732076462017-07-04T15:05:00.000-07:002017-07-06T13:49:33.120-07:00Easton's Route 116 Damaged by Flash Flooding, July 1, 2017<table align="center" cellpadding="0" cellspacing="0" class="tr-caption-container" style="margin-left: auto; margin-right: auto; text-align: center;"><tbody>
<tr><td style="text-align: center;">(For photos of Routes 3, 18, and 112, click <a href="http://burynorthernpass.blogspot.com/2017/07/routes-3-18-112-damaged-by-flash.html">here</a>)<br />
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<span style="font-size: large;"><b><br /></b>
<b>NH DOT Commissioner Sheehan Tours Storm-Damaged </b></span><br />
<b><span style="font-size: large;">Rte. 116, Easton</span></b><br />
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<a href="https://2.bp.blogspot.com/-F7VJYBkQF-8/WVwF7w_pqpI/AAAAAAAAA0g/51ecw3sIG148NOHw9H6xv_rI7MvBBz3qwCLcBGAs/s1600/116%2B02%2BNHDOT%2BEaston.JPG" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" data-original-height="641" data-original-width="573" height="400" src="https://2.bp.blogspot.com/-F7VJYBkQF-8/WVwF7w_pqpI/AAAAAAAAA0g/51ecw3sIG148NOHw9H6xv_rI7MvBBz3qwCLcBGAs/s400/116%2B02%2BNHDOT%2BEaston.JPG" width="357" /></a></td></tr>
<tr><td class="tr-caption" style="text-align: center;"><span style="font-size: 12.8px;">(Posted on NH DOT's Facebook page, July 4, 2017.)</span><br />
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<span style="font-family: inherit; font-size: small;"><b>The following photos were taken in various locations on Rte. 116 </b></span><br />
<span style="font-family: inherit; font-size: small;"><b>in Easton, </b></span><b style="font-family: inherit; font-size: medium;">July 1-5, 2017</b><br />
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<br />Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-30948302148674689302017-06-07T07:41:00.000-07:002017-06-07T07:42:58.945-07:00 Northern Pass would have a catastrophic effect on North Country businesses<div style="font-family: Calibri, Arial, Helvetica, sans-serif; font-size: 16px;">
<u>Littleton Courier</u></div>
<div style="font-family: Calibri, Arial, Helvetica, sans-serif; font-size: 16px;">
June 7, 2017</div>
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<b><br /></b></div>
<div style="font-family: Calibri, Arial, Helvetica, sans-serif; font-size: 16px;">
<b><span style="font-size: 12pt;">Northern Pass would have a catastrophic effect on North Country businesses</span><span style="font-size: 12pt;"></span></b></div>
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<br /></div>
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To the Editor: </div>
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<br /></div>
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I hear comments from people that their credibility was challenged at hearings with Northern Pass. I therefore want to outline my background and thoughts about the impact of Northern Pass underground construction. I am an engineering graduate from MIT and earned an MBA from Harvard Business School. After some years spent at a small CPA firm in Portland, Maine, I became a partner in a national accounting firm working in both Providence, RI and Jacksonville, Fla. Upon retirement, I became a real estate investor. </div>
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<br /></div>
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During my career, I worked with companies both large and small such as Central Maine Power Company, Winn Dixie Stores and Hanford Bros. and banks of all sizes. I also worked with many businesses that had few employees and sole proprietorships, acting as a consultant to those businesses on issues other than financial statements and income taxes. For example, a client might consider a new location and we would discuss the merits and impact of such a step. My function was always to help a business, no matter how small, to survive.</div>
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<br /></div>
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The impact of Northern Pass, where they will take two years from April through November to lay an electric transmission line underground, will be a catastrophe for North Country businesses. Travel will be restricted to one lane in several locations simultaneously on our country roads. Noise, dust, inconvenience and the unsightliness of it all will have only the most loyal and dedicated patrons taking their business elsewhere and oftentimes, as will be the case for tourists, for good. A rural economy, especially one highly dependent on tourism dollars, cannot easily survive this kind of disruption. There just is never an opportunity to make up those lost dollars given that the project is not designed for the purpose of ultimately bringing more customers to the area. Decreased revenue means decreased value in a business affecting resale. The financial consequence of two years loss of income leads to spending retirement savings, already in short supply where it exists at all. </div>
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Yours truly and good luck, </div>
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<br /></div>
<div style="font-family: Calibri, Arial, Helvetica, sans-serif; font-size: 16px;">
Bill Adam </div>
<div style="font-family: Calibri, Arial, Helvetica, sans-serif; font-size: 16px;">
Easton</div>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-39941726762060527542017-04-25T06:51:00.001-07:002017-04-25T06:51:54.325-07:00Granite State Power Link Makes Pitch To LittletonGranite State Power Link Makes Pitch To Littleton<br /><br />No Voiced Concerns Monday<br /><br />Robert Blechl<br />Caledonian Record<br />4/25/2017<br /> <br />LITTLETON — Representatives of Granite State Power Link, the 1,200-megawatt capacity transmission line proposed by National Grid to import Canadian hydro and wind power through the Northeast Kingdom into New Hampshire, made their pitch to Littleton Monday.<br /><br />“Local outreach is essential for what we do with our projects,” GSPL project director Joe Rossignoli said during the regularly scheduled selectmen’s meeting.”We take the local relationship very seriously.”<br /><br />The first of GSPL’s two segments is a new high-voltage direct current overhead line that would run parallel to an existing HVDC transmission line in an expanded right-of-way from the international border at Norton, Vt., through the NEK to Littleton and then to a converter station on National Grid-owned property in Monroe.<br /><br />“The compelling argument is it makes use of existing transmission rights-of-way and that drives down development costs and minimizes visual and environmental impacts,” Rossignoli said of the project.<br /><br />The presentation drew no voiced concerns in Littleton and one expression of support by Selectman Milton Bratz.<br /><br />Referring to Northern Pass, Bratz said, “Five years ago, we took a stand against another project because of cut trees and large towers. I think this addresses the issues we have back then.”<br /><br />Bratz said if his two former select board colleagues were still on the board, they would likely agree.<br /><br />The GSPL differs in several respects from the proposed 1,090-megawatt, $1.6 billion Northern Pass proposal, unpopular with many in the North Country.<br /><br />In addition to GSPL’s $1 billion development cost being funded by the applicant (National Grid) and its investor (Citizens Energy, of Massachusetts) and not ratepayers, the GSPL would have more capacity, would cost more than a third less, and would be almost adjacent to or within existing transmission corridors, with new towers no taller and others smaller than the ones already there.<br /><br />Although Northern Pass representatives said they do not view the GSPL as a competitor, both projects are bidding for the same Massachusetts clean energy request for proposal and there can only be one winner.<br /><br />Because the GSPL will have little to no visual impact and the permitting process is expected to be a smooth one, Rossignoli said he is confident of the GSPL’s chances for the Massachusetts RFP. Bids are due by July.<br /><br />“Last summer we started thinking of ways to get clean energy from Quebec,” he said, adding that some fossil fuel plants in New England are closing and replacement power is needed.<br /><br />The company estimates the existing right-of-way would be expanded 150 feet through segments of the Northeast Kingdom and over the Connecticut River into N.H.<br /><br />In the North Country, 4.6 miles of new line would pass through Littleton and 1.2 through Monroe. Four miles in Littleton and Monroe would use an expanded right-of-way for a new DC line.<br /><br />In all, five miles of line would be in Monroe, eight-tenths of a mile in Lyman, 7.4 miles in Bath, and 8.7 in Haverhill.<br /><br />Only voluntary land acquisition with private landowners will be needed and eminent domain will not be used, said Rossignoli.<br /><br />There will be little to no view shed impact for 106 of the 112 miles in N.H, he said.<br /><br />The second GSPL segment involves upgrading approximately 107 miles of existing National Grid-owned overhead lines from Monroe to southern New Hampshire to accommodate the additional power flows from the new HVDC line.Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-12430899404882556882017-03-27T05:55:00.000-07:002017-03-27T05:55:50.470-07:00New Hampshire State Probe into Northern Pass DeepensAmid Conflicting Statements, State Probes Deeper Into Northern Pass<br /><br />Robert Blechl<br />Caledonian Record<br />March 27, 2017<br /><br />Amid conflicting statements about federal approvals and studies questioning the need for big New England energy projects, the state’s counsel for the public is now asking the burning question – who will pay for Northern Pass?<br /><br />March has been a rocky road for Eversource Energy, parent company of Northern Pass, after its partner, Hydro-Quebec, confirmed it will no longer pay for the estimated $1.6 billion development of the line in the U.S.<br /><br />That reimbursement to Eversource by HQ is in a Transmission Service Agreement approved in late 2010 by the Federal Energy Regulatory Commission and renewed in 2014, with an expiration of February 2017 or another date the partners agree to in writing.<br /><br />After HQ’s announcement, Eversource spokesman Martin Murray said the TSA remains “in full force.”<br /><br />Since then, however, FERC spokesman Craig Cano has confirmed to The Caledonian-Record that HQ and Eversource will need a new approval if the financial arrangement has changed, as HQ said it has.<br /><br />“If the partners develop a different cost recovery mechanism, then they would need to come back to FERC,” said Cano.<br /><br />Who Pays?<br /><br />On March 20, Peter Roth, counsel for the public with the office of the N.H. Attorney General, wrote Eversource attorney Marvin Bellis about who specifically will now pay for the Northern Pass line.<br /><br />“I am concerned that the means for payment and assurance of profitability sought by HQ may have effects on the quantification of the benefits of the project to the people of New Hampshire,” said Roth.<br /><br />Roth noted a contradiction from Eversource stating that HQ “will not pay to bury the line.” On the same day, however, HQ issued a press release stating it “will not pay for the line in the U.S.”<br /><br />As proposed, the 192-mile line would see 7 miles buried in Coos County and 52 miles in Grafton County, with the rest overhead.<br /><br />HQ’s statement about not paying for the line in the U.S. comes after conservation groups in Canada and Quebec’s environmental review board criticized HQ for not burying the line through the Hereford Community Forest near the U.S. border but paying to bury segments of the line in the U.S.<br /><br />Roth seeks clarification on statements made by Eversource that he said contradict statements by HQ.<br /><br />He is also asking Eversource to “please explain how HQ will recover the costs of transmission service for use of the project if HQ and [Eversource] are not successful in the Massachusetts RFP” and if the applicants have any responsibility to pay development costs if the project ever comes to fruition.<br /><br />Roth, too, is asking Eversource to confirm that the TSA filed in 2010 is indeed “the governing agreement between [Eversource] and HQ for paying associated costs with the project and that neither [Eversource] nor HQ are seeking to renegotiate the TSA.”<br /><br />Energy Studies<br /><br />Both ISO-New England and the University of N.H. have issued reports that appear to contradict Eversource’s argument for the need of a large energy projects like Northern Pass.<br /><br />According to the ISO-NE report in May 2015, “The EE [energy efficiency] forecast shows that the energy savings resulting from state-sponsored EE programs can be expected to cause electric energy usage to remain flat in New England as a whole, with energy use in Maine, Massachusetts, Rhode Island, and Vermont, declining by 2024 to levels below those that had been expected in the 2014 EE forecast. The EE forecast also projects that the EE savings will slow the growth in peak demand across the region.”<br /><br />On March 7, UNH’s Carsey School of Public Policy issued a report stating, “New England does not need to increase energy use to continue to grow its economy. From 2005 to 2015, real state GDP in New England grew by 9.7 percent while energy use fell by 9.6 percent. Over the same time period real GDP for the entire U.S. grew by 15.2 percent, while energy use fell by 3.4 percent.”<br /><br />The Carsey report states that during the current period of rapid transformation in energy markets there is significant stranded cost risk to electricity ratepayers for large infrastructure investments with uncertain return on investment.<br /><br />The report concludes, “New England has adapted to higher electricity prices via improvements in energy efficiency and a transition to a less energy-intensive economy. The energy intensity of the New England economy is much lower than the national average.”<br /><br />Murray said Massachusetts has a law specifically requiring its electric utilities to enter into contracts to purchase a large amount of hydro electric energy and off-shore wind energy and Northern Pass will respond to the Massachusetts RFP.<br /><br />Referring to the ISO study, he said the success of the EE does not solve the supply-reliability-price challenge of replacing retiring base-load power plants that help meet demand today.Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-69521935248912017382017-03-10T04:41:00.004-08:002017-03-10T04:41:57.616-08:00Northern Pass - Dead or Alive? <span style="font-family: inherit;"><span style="background-color: white; color: #212121; font-size: 13.3333px;">Northern Pass: Hydro-Quebec Now Unwilling To Pay For Line In U.S.</span></span><br />
<span style="font-family: inherit;"><span style="background-color: white; color: #212121; font-size: 13.3333px;"><br /></span></span>
<span style="font-family: inherit;"><span style="background-color: white; color: #212121; font-size: 13.3333px;">HQ Says Relationship With NP Still Strong, Others Say Project As Proposed Likely Dead</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">Robert Blechl</span></span><br />
<span style="font-family: inherit;">March 10, 2017</span><br />
<span style="font-family: inherit;">Caledonian Record<br style="background-color: white;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">After reports in the Quebec press Wednesday about Hydro-Quebec abandoning Northern Pass, the Canadian company responded Thursday to say it has no intention of pulling out of its relationship with Eversource Energy, its American partner.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">One thing that has changed, however, and significantly, is that HQ is no longer willing to pay for the NP line in the United States and wants Massachusetts rate payers to pick up the tab.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">That announcement, confirmed by Hydro-Quebec, is a break from the 2011 Transmission Service Agreement between HQ and NP parent company, Eversource Energy, that states HQ would reimburse Eversource for all development costs of the now-estimated $1.6 billion NP transmission line.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">That change, in short, means HQ is unwilling to assume all the risk of the project and it now calls into question if it makes economic sense for either partner to proceed with the project as it’s currently proposed.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">“Facts on the ground have changed,” said Bob Baker member of the North Country-based Responsible Energy Action LLC, a citizens’ education, advocacy and action group focused on N.H. energy policy.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">“The transmission line now costs at least half a billion more than originally planned,” he said. “The capacity of the line has been reduced by 20 percent. The wholesale market price of electricity in New England is lower than its been in 13 years. So the original deal no longer makes sense. It is dead. If there is a new deal, it is slowly being revealed by reading between the inconsistent lines published by HQ and Eversource on their respective sides of the border. HQ is no longer willing to take on the risk of loss.”</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">HQ’s announcement came after a Wednesday story in Le Journal de Quebec stating HQ would be paying for the line in the U.S.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">In a press release Thursday, HQ said “it has no intention to abandon the project” and “wishes to reiterate the position we shared with numerous Quebec media on Wednesday: Hydro-Quebec will not pay for the line in the U.S. [and] Hydro-Quebec will make sure this project is profitable for Quebecers.”</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">HQ said it now intends to submit the project to the request for proposals that Massachusetts will soon be issuing.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">It is unclear, however, if HQ and Eversource N.H. have a renewed Transmission Service Agreement filed with the Federal Energy Regulatory Commission.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">In December 2013, Eversource requested an amendment to its 2011 TSA with HQ, noting delays in the project and stating, “The parties have agreed to replace the term ‘third anniversary’ with the term ‘approval deadline,’ which is defined to mean Feb. 14, 2017, or such other date to which the parties shall mutually agree in writing.”</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">Spokespersons at FERC said that to date there is no signed and renewed TSA between Eversource and HQ on file.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">On Thursday, Eversource spokespersons Martin Murray and Kaitlyn Woods declined to say if Eversource has a renewed TSA with HQ, what the terms of it are, and if it plans to present it to investors to assure them HQ will remain committed and Northern Pass as proposed is moving forward.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">Baker said just like the first TSA amendment proposed in December 2013, the parties would want to file it 60 days beforehand to get a FERC approval by February. That hasn’t happened.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">In the 2011 TSA, Eversource didn’t take any real risk and the risk was mostly on HQ, said Baker.</span><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><br style="background-color: white; color: #212121; font-size: 13.3333px;" /><span style="background-color: white; color: #212121; font-size: 13.3333px;">“This is how it’s changed,” he said. “HQ now says we will only build NP if the rate payers in New England, and especially in Massachusetts, pay for the transmission line through a long-term contract where they agree to a high rate … They are not going to do the project unless they are guaranteed a payback … They don’t see the profit under the original model.”</span></span>Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-74245046241723080802016-12-27T15:09:00.000-08:002016-12-27T15:45:57.276-08:00Mostly Small NH Towns v. Big Utilities<br />
<b>North Country Towns Gear Up For N.H. Supreme Court Fight Against Big Utilities</b><br />
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<b><br /></b></div>
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<b>Argue State Allowing Utilities To “Escape Taxation”</b><br />
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<b><i>Case to be heard Jan. 5, 2017</i></b></div>
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<br />
Robert Blechl<br />
<div>
Caledonian Record<br />
Nov 26, 2016 <br />
<br />
<div>
Municipalities across the state, including many in the North Country, have filed argument briefs in their years-long tax abatement fight against two big utilities, a case now scheduled to be heard before the N.H. Supreme Court Jan. 5.<br />
<br />
The municipalities argue the appraisals provided by Eversource Energy and the New Hampshire Electric Cooperative as well as by the New Hampshire Department of Revenue Administration in towns are unreliable, do not provide an opinion of the value of the actual assets in the individual towns, and the DRA’s “net book approach … allowed property to escape taxation.”<br />
<br />
At stake for the two utilities are millions of dollars saved through significantly reduced property taxes, a potential boost to company profits.<br />
<br />
At stake for small towns, which argue the utilities are trying to get out of paying their fair share of taxes, is a reduction in tax revenue that could put a strain on town services and increase the taxes of all other taxpayers.<br />
<br />
In July 2015, the New Hampshire Board of Tax and Land Appeals ruled in favor of the towns, concluding the unit method of valuation sought by Eversource and NHEC - a method through which they seek to reduce their property taxes by one-half to two-thirds - does not represent the fair market value of the utility properties.<br />
<br />
Eversource and NHEC promptly appealed to the New Hampshire Supreme Court.<br />
<br />
Representatives for Eversource have equated higher property taxes with increased costs for ratepayers, but neither utility has provided a guarantee that rates would be reduced or stay the same if their property taxes were likewise reduced.<br />
<br />
The New Hampshire Public Utilities Commission, which regulates utilities, is the entity that approves or denies a requested rate increase.<br />
<br />
In its argument brief filed with the New Hampshire Supreme Court in September, Eversource argues it faces regulatory restraints on income and operations and that “dramatically inconsistent assessments, including assessments more than doubling in one year in one community,” compelled it to file the appeals.<br />
<br />
Eversource also claims the DRA establishes the market value of utility property for the state utility tax and municipal assessments “vary widely” from the DRA’s valuations.<br />
<br />
In an argument brief filed at the New Hampshire Supreme Court in early November, however, attorneys for the towns argue, “Over 50 years ago, this court recognized that using net book to value utility property is inherently unfair and impractical because, in part, it does not address the changes in the of the assets that occur over long periods of time.”<br />
<br />
The towns also took aim at the DRA, the agency responsible for supervising assessments in the state, which they charge with providing appraisals with errors and allying with the two utilities at the expense of the towns they represent.<br />
<br />
In its brief, the DRA argues the BTLA ruling jeopardizes the state’s equalization process, which it said relies on the allocated values from the DRA appraisals and puts at risk the local assessments in about one-third of all N.H. municipalities that use the DRA utility property appraisal values for local tax assessing.<br />
<br />
If the BTLA ruling stands, the DRA argues, the utility property tax that the agency said last year generated nearly $43 million in revenue could be undermined.<br />
<br />
What the agency did not say in its argument, however, is if utility property values in some towns are being unnecessarily under-assessed.<br />
<br />
In many small towns, utility property makes up a large chunk of their tax base, which, if they lose the case, could erode by millions of dollars.<br />
<br />
The municipalities also argue the DRA is not being transparent and is not allowing selectmen and the public to review the basis for the agency’s valuation for local tax purposes.<br />
<br />
“Basically, the DRA is saying ‘trust us, we’ll get it right, and we are not going to allow anyone to check our work,” attorneys Jae Whitelaw, Christopher Boldt and Shawn Tanguay, representing the towns, wrote in their brief. “This effort at reassurance rings hollow.”<br />
<br />
Stephan Hamilton, director of the DRA’s Municipal and Property Division, was contacted several times about the case, but declined to comment.<br />
<br />
Some towns have been spending tens of thousands of dollars annually fighting the appeals that began in 2011 and have continued each year thereafter.<br />
<br />
Eversource, the largest electric utility in New Hampshire, is suing about one-quarter of New Hampshire’s municipalities, most of them small towns and including Littleton, Bath, Haverhill, Lancaster, Dalton, Northumberland, Whitefield, Landaff, Stark, Stratford and Stewartstown.</div>
<div>
<br />
In Littleton, Eversource is seeking to reduce its total assessment of about $22 million to $11 million.<br />
<br />
In Lancaster, for the 2011 tax year, the company wants to cut its assessment from $7.38 million to $3 million.<br />
<br />
NHEC’s tax abatement appeals, filed at both the BTLA and superior court, are against towns that include Bath, Colebrook, Haverhill, Landaff, Littleton, and Monroe.<br />
<br />
Representing the two utilities at the Jan. 5 oral argument before the state’s high court will be attorney Margaret Nelson. Representing the DRA will be Assistant New Hampshire Attorney General Laura Lombardi. Representing the towns will be attorneys Boldt, Tanguay, and Walter Mitchell.<br />
<br />
The case could have widespread ramifications on utility property appraisal in the future, beyond the two current utilities.<br />
<br />
Since the appeals were filed, three more utilities also standing to gain through reduced property taxes have filed briefs in support of Eversource and the NHEC - Unitil Energy Systems, Northern Utilities, and Granite State Gas Transmission.<br />
<br />
<div style="text-align: center;">
###</div>
<div style="text-align: center;">
<i><br /></i></div>
<div style="text-align: left;">
<i>Towns named in the suits include: Andover, Bridgewater, Croydon, Danville, Durham, Dunbarton, Fremont, Littleton, New Hampton, Pembroke, Randolph, Sandwich, Sunapee, Bath, Bradford, Bristol, Landaff, Milan, Bennington, Chester, Dalton, Hampstead, Haverhill, Hinsdale, Hopkinton, Lancaster, Lincoln, Madison, Marlborough, Newport, Pelham, Raymond, Springfield, Stratford, Washington, Whitefield, Unity, Hinsdale, Plymouth, Antrim, East Kingston, Francestown, Gorham, Greenville, Henniker, New Ipswich, Northfield, South Hampton, Stark, Stewartstown, Stoddard, Warner, Wilmot, Nelson, Hollis, Northumberland, Colebrook, Monroe. (58)</i></div>
</div>
</div>
</div>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-70680133218143835182016-12-24T04:34:00.001-08:002017-12-26T12:53:30.975-08:00Steve Ellis: Town roads and Northern Pass's back door eminent domain<i><b><br /></b></i>
<i><b><br /></b></i>
<b><i>On December 20, 2016, 18 New Hampshire municipalities and others filed a petition asking the SEC to rule that Northern Pass does not have the legal right to use locally-maintained town roads without municipal permission. Project applicants have been proceeding without such municipal permission. The petition contains appendices with affidavits from property owners whom the Applicants paid in order to perform required geotechnical surveys on their private land next to town roads in Stewartstown. Following is a summary of the petition, with a link to the full text, news reports, and a letter by Steve Ellis, chair of the Pittsburg Select Board, asking other NH municipalities to support the petition at the SEC. This matter, Ellis notes, affects all NH towns and cities and is larger than the issue of Northern Pass per se.</i></b><br />
<br />
(<span style="color: orange;"><b><u>See the end of this post for the January 4, 2017 update</u><span style="color: orange;">.</span></b></span>)<br />
<div style="text-align: center;">
<i><b><br /></b></i></div>
<div style="text-align: center;">
<span style="font-size: large;"><b>PETITION TO THE SEC FOR DECLARATORY RULIN</b>G </span></div>
<br />
The Town of Bethlehem, Town of Bridgewater, Town of Bristol, Town of Clarksville,
City of Concord, Town of Deerfield, Town of Easton, Town of Franconia, Town of Littleton,
Town of New Hampton, Town of Northumberland, Town of Pembroke, Town of Pittsburg,
Town of Plymouth, Town of Stewartstown, Town of Sugar Hill and Town of Whitefield, Town
of Woodstock, the Ashland Water and Sewer Department, the Society for the Protection of New
Hampshire Forests, and the Appalachian Mountain Club (the "Petitioners"), pursuant to New
Hampshire Administrative Rule Site 203.01, respectfully petition the New Hampshire Site
Evaluation Committee (the "SEC" or "Committee") to issue a declaratory ruling stating that,
pursuant to RSA 231: 160 et seq, only municipalities have the authority to authorize or not
authorize the erection, installation, or maintenance of electric power poles or structures or
underground conduits or cable, or their respective attachments or appurtenances, on, across, or
under locally maintained highways, regardless of whether the New Hampshire Department of
Transportation (the "NHDOT"), the SEC, or other agencies have authority to permit or license
other portions of any proposed facility.<br />
<i><br /></i>
<i>Read the full petition to the SEC by 18 NH towns et al. <a href="https://www.forestsociety.org/sites/default/files/Petition%20for%20Declaratory%20Ruling%2012-19-16.pdf">here.</a></i><br />
<br />
<b><span style="font-size: large;">News reports</span></b>:<br />
<br />
<a href="http://www.colebrookchronicle.com/Dec232016.pdf">"Northern Pass Looking to Avoid Town Permitting?</a>," by Donna Jordan.<br />
<br />
<a href="http://indepthnh.org/2016/12/23/when-it-comes-to-northern-pass-who-controls-the-roads/">"When It comes to Northern Pass, Who Controls the Roads?,"</a> by Nancy West.<br />
Reprinted in the <u>Berlin Daily Sun</u>, <u>Conway Daily Sun</u>, and <u>Union Leader.</u><br />
<a href="http://www.caledonianrecord.com/news/local/towns-use-home-rule-strategy-in-northern-pass-fight/article_28ea2fd5-735e-5556-b2b8-acb2712c362c.html"><br /></a>
<a href="http://www.caledonianrecord.com/news/local/towns-use-home-rule-strategy-in-northern-pass-fight/article_28ea2fd5-735e-5556-b2b8-acb2712c362c.html">"Towns Use 'Home Rule' Strategy in Northern Pass Fight,"</a> by Robert Blechl.<br />
Reprinted in <u>Union Leader</u>.<br />
<a href="https://www.forestsociety.org/blog-post/nh-towns-assert-authority-over-local-roads-regarding-northern-pass"><br /></a>
<a href="https://www.forestsociety.org/blog-post/nh-towns-assert-authority-over-local-roads-regarding-northern-pass">"NH Towns Assert Authority over Local Roads Regarding Northern Pass,"</a> by Jack Savage.<br />
<a href="http://www.wcax.com/story/34115922/18-nh-towns-seek-more-local-control-over-northern-pass-siting"><br /></a>
<a href="http://www.wcax.com/story/34115922/18-nh-towns-seek-more-local-control-over-northern-pass-siting">"18 NH Towns Seek More Local Control over Northern Pass Siting</a>," AP report.<br />
<br />
"<a href="http://www.colebrookchronicle.com/Jan62017.pdf">SEC to Review Petition on Northern Pass Road Use</a>," by Donna Jordan (1/2/2017).<br />
<div>
<br /></div>
<br />
<b><span style="font-size: large;">Steve Ellis's letter to NH municipalities</span></b><br />
<br />
December 20, 2016<br />
<br />
TO: New Hampshire Boards of Selectmen<br />
New Hampshire City Mayors and Governing Boards<br />
New Hampshire Town Councils<br />
<br />
FROM: Steve Ellis, Chair, Town of Pittsburg, Board of Selectmen<br />
<br />
SUBJECT: Local Control of Municipal Roads<br />
<br />
I write on behalf of the Boards of Selectmen in Pittsburg, Clarksville and Stewartstown, to share
with you a concern we have about the legal control of municipal roads and how the established
principle of home rule applies to the continued ability of municipalities to retain control over
municipal roads. I also write to ask you to consider writing a letter to defend the principle of
home rule as it relates to municipal roads.<br />
<br />
Our concern arises over a claim by the region's largest electric utility (Eversource) that they have
the right to appropriate municipal transportation rights of way without any consultation or
approval from the municipal governing authority to build a high voltage electric transmission
line within the right of way. In fact, <a href="http://www.gencourt.state.nh.us/rsa/html/XX/231/231-161.htm">RSA 231:161</a> clearly provides that
municipal governing bodies have the exclusive authority to permit and license such uses of
municipally owned rights of way. Eversource, the developer of the Northern Pass project,
claims that the New Hampshire Site Evaluation Committee has the power to preempt this statute.
Nothing in the statute authorizing the Site Evaluation Committee (RSA 162-H) sets aside the
statutory provisions in RSA 231: 161. Eversource lamely argues that a prior Supreme Court case
with an entirely different set of facts supports their claim. An excerpt from the Northern Pass
application to the SEC making this claim [follows, below].<br />
<br />
Follow this link to the Supreme Court
decision cited by Northern Pass: <a href="https://www.courtlistener.com/opinion/2111618/public-servco-v-town-of-hampton/">https://www.courtlistener.com/opinion/2111618/public-servco-v-town-of-hampton/</a><br />
<br />
Our three towns have joined with a number of other intervenors in the Northern Pass docket at
the SEC to ask the SEC to initiate a new docket to specifically address this dispute. Under SEC
rules, any party can file a request for a declaratory ruling for the purpose of addressing matters
within the SEC's jurisdiction. A copy of our filing made December 19 is [<a href="https://www.forestsociety.org/sites/default/files/Petition%20for%20Declaratory%20Ruling%2012-19-16.pdf">here</a>] for your
review.<br />
<br />
Whether one is for, against or agnostic on the issue of Northern Pass, it is the height of arrogance
(not to mention against the law) for a large domestic utility partnering with a large foreign utility
to commandeer for their exclusive financial benefit a municipal transportation corridor without
the acquiescence of the municipality. In the six years since Northern Pass was first announced, project developers have never formally or informally asked our towns' permission to use town
roads for their project. Their application to the SEC has a single blank license form for the
locations within our three towns where they propose to bury their facility along more than 8
miles of municipally maintained roads. The Legislature has precluded Northern Pass from
having access to eminent domain for the purpose of condemning private property for their
project. However, RSA 231: 167 provides that if a landowner has suffered damage as a result of
the installation, the landowner may apply to the Selectmen to assess damages in the same manner
as laying out a new road. In other words, the Town would be liable for the taking and
responsible for paying the damages assessed, not Northern Pass. Northern Pass is thus shifting
the burden of eminent domain - a power it does not possess - to the Towns, while arguing that
the towns have no say in the matter.<br />
<br />
This back-door condemnation of municipal roads must not be allowed to stand. I ask you to
consider writing a letter to the SEC in support of our petition, opposing the Eversource attempt
to secure through the back door what they cannot achieve through the front door. Please direct
your comments to: Ms. Pamela Monroe, Administrator, NH Site Evaluation Committee, 21 Fruit
Street, Concord, NH 03301. Or e-mail your comments to Pamela.Monroe@sec.nh.gov.<br />
<br />
Thank you for your consideration of this request.<br />
<br />
<br />
<div style="text-align: left;">
---------------------</div>
<br />
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<div align="center" class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-align: center; text-autospace: none;">
<b><u><span style="font-family: "times new roman" , "serif"; font-size: 12.0pt;">FROM
PAGE 82-83 of NORTHERN PASS SEC APPLICATION,<o:p></o:p></span></u></b></div>
<div align="center" class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-align: center; text-autospace: none;">
<b><u><span style="font-family: "times new roman" , "serif"; font-size: 12.0pt;">Submitted
October 19, 2015<o:p></o:p></span></u></b></div>
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<br /></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<b><span style="font-family: "times new roman" , "serif";">(D) Crossing Local Highways<o:p></o:p></span></b></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">NPT seeks permission to install the Project,
including conduit, cable, wires, poles, structures and devices across, over,
under and along certain locally-maintained highways, including 71 aerial
crossings and four underground roadway installation sections. The underground
sections are identified by town and roadway. The SEC has exclusive authority to
grant permission to an energy facility to utilize locally-maintained highways.
In <i>Public Service Company of New Hampshire v. Town of Hampton, </i>120 N.H.
68 (Jan. 31, 1980), the Court pointed out that the “declared purposed of RSA
ch. 162-F [forerunner to RSA ch. 162-H] is to provide a resolution, in an ‘integrated
fashion,’ of all issues involving the routing of transmission lines.” The Court
found that the Town of Hampton could not regulate transmission lines associated
with the Seabrook Nuclear Station, noting that the SEC protects the public
health and safety of towns with respect to transmission lines covered by the
siting statute. NPT has filed a request with the NHDOT to cross
state-maintained highways and has included that request with the Application as
required by RSA 162-H:7 and Site 301.03 (d). See Appendix 9.<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<br /></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">RSA 162-H:16, IV provides that the SEC must find,
among other things, that issuance of<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">a certificate of site and facility will not have an
unreasonable adverse effect on public health and<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">safety. Utilities of all varieties, including power lines,
have long been recognized as appropriate<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">users of public highways, so long as the facilities
do not conflict with the general public’s<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">superior use. E.g., <i>McCaffrey v. Concord Electric
Co., </i>80 N.H. 45, 46-47 (1921). In <i>King v.<o:p></o:p></i></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<i><span style="font-family: "times new roman" , "serif";">Town of Lyme</span></i><span style="font-family: "times new roman" , "serif";">, 126 N.H. 279, 284 (1985), the
Court affirmed that a utility’s use of a highway<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">easement is appropriate since New Hampshire has
never considered highway purposes to be<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">limited to the transportation of movable vehicles,
persons or property. The authority to
erect electric transmission lines and underground cables in state and local
highways is codified at RSA 231:160. The standard for locating poles, lines,
and underground cables is set forth at RSA 231:168, which states that the lines
“will not interfere with the safe, free and convenient use for public travel of
the highway.” To further that process, the NHDOT has adopted certain standards,
which are set forth in its <i>Utility Accommodation Manual </i>(“UAM”), dated
February 24, 2010. This filing constitutes notice of these proposed crossings,
associated pole placements and locations in accordance with the procedures set
forth in the UAM Appendix G-3.1-2.<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";"><br /></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">The New Hampshire Supreme Court has made it clear
that the authority to license placement of power lines, poles and underground
conduit within highways is regulatory in character and must be exercised in a
non-exclusionary and reasonable manner. In <i>Rye v. Public Service Company of
New Hampshire</i>, 130 N.H. 365 (1988), the Court found that a crossing application
may be denied only for a public safety-based reason.<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<br /></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">NPT seeks approval from the SEC to install its
Project within, along, over, under and<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">across locally-maintained highways. This request
mirrors the approach followed, and the<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">standards applied, in the request made to NHDOT for
state-maintained highways. With respect<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">to the underground highway installation sections in
the towns of Clarksville and Stewartstown,<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">NPT proposes that the SEC apply the NHDOT <i>Standard
Specifications for Road and Bridge<o:p></o:p></i></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<i><span style="font-family: "times new roman" , "serif";">Construction </span></i><span style="font-family: "times new roman" , "serif";">and the provisions, instructions,
and regulations set forth in the NHDOT’s standard<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">Excavation Permit. Furthermore, NPT proposes that
the SEC condition approval of a certificate,<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">to the extent necessary, on compliance with such
standards. Accordingly, Project plans for aerial<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">crossings and underground sections within highways
are provided at the 30% design level, which<o:p></o:p></span></div>
<div class="MsoNormal" style="line-height: normal; margin-bottom: .0001pt; margin-bottom: 0in; mso-layout-grid-align: none; text-autospace: none;">
<span style="font-family: "times new roman" , "serif";">is the commonly accepted level of detail for initial
permit applications and consistent with<o:p></o:p></span></div>
<br />
<div class="MsoNormal">
<span style="font-family: "times new roman" , "serif";">NHDOT
practice. See Appendix 9 and 10.</span><o:p></o:p><br />
<span style="font-family: "times new roman" , "serif";"><br /></span>
<br />
<div style="text-align: center;">
<span style="font-family: "times new roman" , "serif";">###</span></div>
<div style="text-align: center;">
<span style="font-family: "times new roman" , "serif";"><br /></span></div>
<div style="text-align: left;">
<span style="font-family: "times new roman" , "serif";"><b><u>January 4, 2017 Update</u></b></span></div>
<div style="text-align: left;">
<span style="font-family: "times new roman" , "serif";"><br /></span></div>
<div style="text-align: left;">
<span style="font-family: "times new roman" , "serif";">The SEC has opened a new docket (2016-03) on the petition <a href="http://www.nhsec.nh.gov/projects/2016-03/2016-03.html">here.</a></span></div>
<div style="text-align: left;">
<br /></div>
<div style="text-align: left;">
Anyone may enter a public comment on the petition; it will be posted in the "comments" section of this docket.<br />
<br />
Make reference to "Docket 2016-03" in your comment and include your residential address.<br />
<br />
Email your comment to the SEC Administrator, Ms. Pamela Monroe, at pamela.monroe@sec.nh.gov.<br />
<br />
The SEC will hold a meeting on <u>January 12, 2017</u>, starting at 11:00 AM, to discuss plans for proceeding on this docket. The location for the meeting is the PUC, Fruit Street, Concord.<br />
<br />
<b><u>Further action in Docket 2016-03</u></b><br />
<br />
On March 7, 2017, the SEC <a href="https://www.nhsec.nh.gov/projects/2016-03/orders-notices/2016-03_2017-03-07_order_dismissing_pet.pdf">dismissed</a> the petition for declaratory ruling, followed by the Forest Society's motion for rehearing, the Applicants' objection, and the Forest Society's Supplement to its motion for rehearing (April 12, 2017).<br />
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<br />Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-2914694679450144642016-09-21T05:02:00.001-07:002016-09-23T07:50:08.787-07:00Hydro Quebec's mind boggling profit makes Northern Pass burial look more "economic" every day<div rtenodeid="3" style="font-family: Calibri, Arial, Helvetica, sans-serif; font-size: 16px;">
<strong>Line burial looks more “economic” every day </strong></div>
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<u>Coos County Democrat</u><br />
<u>Littleton Courier</u> </div>
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September 21, 2016<br />
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Editorial</div>
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As the President and Chief Executive Officer of Hydro-Québec, Éric Martel spends a lot of time smiling. Who cares, he probably thinks, that the company's profit was $37 million less in the second quarter of 2016 compared to the same period in 2015. After all, for the first six months of this year, the company posted a profit of nearly $1.9 billion. Once again, this editor would like to congratulate the foreign monopoly for making so much money. He would also like to ask why Martel does not seem interested in using some of Hydro-Québec's $432,692 of hourly profit to completely satisfy residents of Northern New Hampshire. As the entity that would build Northern Pass, the hydropower transmission project through our state, Hydro-Québec has plenty of money to fully bury the project. </div>
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Previously, this editor used the figure of $370,000 to describe Hydro-Québec's hourly profit. Mr. Martel and his company keep finding ways to bring home more bacon. Now making about $60,000 an hour more compared to last year, no rational argument can be made that Northern Pass cannot afford the approximately $1 billion of extra cost to fully bury the power line. Hydro-Québec can make nearly that much money in an average three-month span. </div>
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The project likes to say that full burial is “uneconomic” for Northern Pass. They say this because the foreign shareholders of Hydro-Québec would prefer to put their massive profits elsewhere. No one can say with a straight face that completely burying Northern Pass is anything but “economic,” due to how much money Hydro-Québec keeps making. Many people in our region work really hard all year without making ten percent of what Hydro-Québec takes to the bank in an hour. Hopefully, the company and Northern Pass will stop insulting our intelligence by saying the money just is not there to make invisible the 130 miles of proposed aboveground lines.</div>
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Just in proposed form, without a speck of dirt moved to construct the project, Northern Pass can do much to alter the order of things in our region. Sugar Hill's Dolly McPhaul took her intense opposition to the project on the road during a Republican primary campaign for State Senate. Without having held elective office before, McPhaul defeated a highly experienced elected official who many rightfully deemed as wishy washy on Northern Pass. The result of the primary contest has issued a warning to all politicians who seem closer to the billions Hydro-Québec makes than the perspective of residents in our region who simply cannot accept Northern Pass as proposed. And this editor would once again like to say to our elected officials: resign if you cannot side with the people of this region demanding that Éric Martel pay for a fully buried Northern Pass that makes New Hampshire happy.</div>
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An old saying notes, “To whom much is given, much is required.” Congratulations, once again, to Éric Martel and the economic powerhouse of a company he leads. Much has been given to him. Now it is finally time, nearly six years after Northern Pass was first proposed, that the project is required to spend the dollars necessary to completely bury the transmission lines. Martel can make all the money he wants. He simply should not be allowed to change so much about New Hampshire while pocketing a mind boggling amount of money.</div>
Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-51496269312459372872016-08-03T05:36:00.000-07:002016-08-03T05:36:16.301-07:00An Icy Glare from Northern Pass Coos County Democrat<br />
August 3, 2016<br />
Editorial<br />
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<span style="font-size: large;">An icy glare from Northern Pass</span></div>
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In May, the New Hampshire Department of Environmental Services issued a letter about Northern Pass. DES appeared to suggest that the 192-mile hydropower transmission project needed to do more to minimize construction impacts on wetlands and other sensitive areas. The regulator's letter pointed toward the desirability of a new route and more line burial in Coös County. Although DES was not making official conclusions against issuance of needed permits, Northern Pass must have felt some doubts about the viability of the project's preferred route. With a recent response to DES, however, the project gave an icy glare to a regulatory entity.<br /><br />This editor must give some credit to Northern Pass. The project's financial backers have already spent a great deal of money examining the project's impacts on wetlands. In public hearings and letters, some critics of Northern Pass concede the the project's wetlands analysis was well done. Northern Pass is not just going through the motions on the application process. There seems to be a legitimate interest in decreasing certain wetlands impacts while promoting the state fund that provides money to protect wetlands in other parts of the state.<br /><br />However, the project may not have made the best decisions in the recent response to DES. Instead of really detailing the project's commitment to lessening impacts on the environment, Northern Pass stressed how the state cannot push back too hard. By doing so, Northern Pass suggested time and again, the big money making dream that is the proposed transmission line might not happen. The DES ideas on further line burial to protect more wetlands "is not practicable," Northern Pass brazenly asserted.<br /><br />The state's Site Evaluation Committee, which will make the call on whether the project receives a construction permit, should be watching the Northern Pass wetlands debate quite closely. As the project keeps its eye on the prize, earning billions of dollars over the next few decades, the SEC needs to remember who the big money maker from Northern Pass will be, Hydro Quebec. The company, as this editor likes to say over and over again, makes $370,000 of profit every hour. Regardless of what Northern Pass wants state regulators to believe, Hydro Quebec has plenty of money to fully bury the project in a way that satisfies New Hampshire. The extra $1 billion to achieve complete burial might make Northern Pass "uneconomic" to those whose first desire is to placate a foreign monopoly like Hydro Quebec. But the project needs to remember that regulators must be satisfied with how issues like wetlands impact are resolved.<br /><br />The late Ray Burton inspired us in so many ways. Perhaps his finest hour occurred during testimony at Northern Pass hearings. Burton said Hydro Quebec needs to find the money to fully bury the line, or fold its tent and go home. Anyone examining Hydro Quebec's financial statements can see the money is there. Just because the company does not want to spend four months of profit to make New Hampshire happy does not mean state regulators must fall into line. DES, the SEC, and all other state entities with a dog in the Northern Pass fight must remember that they work for us, not the shareholders of a foreign government. Northern Pass will place Hydro Quebec's financial well being at the forefront, but there is no reason for regulators to cower before the mighty monopoly. The residents of the North Country certainly are not doing so.<span style="font-family: Nimrod MT,Nimrod MT; font-size: x-small;"><span style="font-family: Nimrod MT,Nimrod MT; font-size: x-small;"><div align="CENTER">
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</span></span>Unknownnoreply@blogger.comtag:blogger.com,1999:blog-4402631160035830422.post-81020411305629581132016-07-23T08:37:00.000-07:002016-07-23T09:27:11.118-07:00CFP's August 9th meeting on NPT for Town Conservation Commissions<div style="text-align: left;">
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<span style="font-family: "IowanOldStyle-Black","sans-serif"; font-size: 25.5pt; mso-bidi-font-family: IowanOldStyle-Black;">New Hampshire Association<o:p></o:p></span></div>
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<span style="font-family: "IowanOldStyle-Black","sans-serif"; font-size: 24pt; mso-bidi-font-family: IowanOldStyle-Black;">of Conservation Commissions<o:p></o:p></span></div>
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<span style="font-family: "IowanOldStyle-Black","sans-serif"; mso-bidi-font-family: IowanOldStyle-Black;"><span style="font-size: small;">SERVING NEW HAMPSHIRE’S COMMUNITIES SINCE 1970<o:p></o:p></span></span></div>
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<span style="font-size: small;"><span style="font-family: "IowanOldStyle-Black","sans-serif"; mso-bidi-font-family: IowanOldStyle-Black;">54 Portsmouth Street, Concord, NH 03301 | (603) 224-7867 |</span><b><span style="font-family: "Optima-Bold","sans-serif"; mso-bidi-font-family: Optima-Bold;"><o:p></o:p></span></b></span></div>
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<span style="font-size: small;"><b><span style="font-family: "Optima-Bold","sans-serif"; mso-bidi-font-family: Optima-Bold;">Date:
</span></b><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">July 19, 2016<o:p></o:p></span></span></div>
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<span style="font-size: small;"><b><span style="font-family: "Optima-Bold","sans-serif"; mso-bidi-font-family: Optima-Bold;">To:
</span></b><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">Conservation Commission Members affected by Northern Pass
proposal<o:p></o:p></span></span><br />
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<span style="font-size: small;"><b><span style="font-family: "Optima-Bold","sans-serif"; mso-bidi-font-family: Optima-Bold;">Subject:
</span></b><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">Meeting with Counsel for the Public, Peter Roth and Associates<o:p></o:p></span></span></div>
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<span style="font-size: small;"><b><span style="font-family: "Optima-Bold","sans-serif"; mso-bidi-font-family: Optima-Bold;">When:
</span></b><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">Tuesday, August 9, 6 pm at Conservation Center, 54 Portsmouth
St. Concord<o:p></o:p></span></span></div>
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<span style="font-size: small;"><b><span style="font-family: "Optima-Bold","sans-serif"; mso-bidi-font-family: Optima-Bold;">Re:
</span></b><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">Northern Pass Proposal before the NH Site Evaluation Committee
(SEC)<o:p></o:p></span></span></div>
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<span style="font-size: small;"><b><span style="font-family: "Optima-Bold","sans-serif"; mso-bidi-font-family: Optima-Bold;">From:
</span></b><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">Barbara Richter, Executive Director, </span></span><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">New
Hampshire Association of Conservation Commissions<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">_______________________________________________________________<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">As you know,
the Northern Pass transmission line proposal (SEC Docket #2015-06) is<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">currently
under review by the NH Site Evaluation Committee. This process is governed by<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">NH RSA 162-H
and Administrative Rules # Site 100- Site 300. RSA 162-H:9 provides for a<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">Counsel for
the Public with the duty to “represent the public in seeking to protect the quality<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">of the
environment and in seeking to assure an adequate supply of energy.” Peter Roth
is<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">currently
the Counsel for the Public.<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">Mr. Roth has
asked our office to assist him to organize a meeting of conservation commission<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">members in
affected communities along the proposed route. Given that the proposed<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">transmission
line would cover 192 miles within the state, the logistics of such a meeting
will<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">be
cumbersome at best.<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><o:p><span style="font-size: small;"> </span></o:p></span><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">While the
NHACC Board of Directors voted not to take a position on the Northern Pass<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">proposal, we
do recognize the need for information exchange, especially with the Counsel for<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">the Public
who is responsible for representing the public interest before the SEC. We have<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">agreed to
assist him in this effort. Conservation commissions have unique knowledge about<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">the natural
resources, protections, ordinances and special circumstances within your<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">communities.
This meeting will provide an opportunity to share this vital information with<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">Mr. Roth who
will review this information with his experts to better represent the public<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">interest
before the Site Evaluation Committee.<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">We will be
able to use meeting space here at the Forest Society’s Conservation Center and
we<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">realize that
not everyone is able to attend at this time. For those with timing or distance<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">constraints,
we could work with you to either call or video chat into the meeting.<o:p></o:p></span></span></div>
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<span style="font-size: small;"><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">Please let
me know whether you </span><b><i><span style="font-family: "Optima-BoldItalic","sans-serif"; mso-bidi-font-family: Optima-BoldItalic;">will be able to attend </span></i></b><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">this
meeting.<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">Also, since
information is key, could you please provide copies of your town’s conservation<o:p></o:p></span></span></div>
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">plan,
natural resource inventory or other pertinent reports you have in either
electronic or<o:p></o:p></span></span></div>
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<span style="font-size: small;"><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">hard copy
format </span><b><i><span style="font-family: "Optima-BoldItalic","sans-serif"; mso-bidi-font-family: Optima-BoldItalic;">directly to me either via e-mail or
hard copies </span></i></b><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;">so we may coordinate it and<o:p></o:p></span></span></div>
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</span><br />
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<span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">get the information to Mr. Roth in advance
of the meeting.<o:p></o:p></span></span></div>
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</span><span style="font-family: "Optima-Regular","sans-serif"; mso-bidi-font-family: Optima-Regular;"><span style="font-size: small;">_______________________________________________________________</span></span><br />
<span style="font-size: small;">
</span></span>NHACC contact info: <a href="http://www.nhacc.org/contact/">http://www.nhacc.org/contact/</a></div>
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