Northern Pass Transmission’s amended application for a presidential permit filed in July misrepresents the impacts of the proposed 345-kV project, relies upon outdated and inaccurate data and analysis and fails to provide certain information, according to the New England Power Generators Association (NEPGA).
The U.S. Department of Energy (DOE) should deem that the amended application is not complete and should not be accepted for filing and consideration at this time, NEPGA said in its Sept. 18 comments filed with DOE. In the alternative, the “numerous inaccuracies” should be struck from the amended application and DOE should direct Northern Pass to provide more accurate information.
The amended application filing is premature as Northern Pass admittedly does not have site control over the proposed transmission line route, the association said.
According to NEPGA, Northern Pass filed the amended application on July 1 regarding its proposal to build the transmission line from Quebec to New Hampshire in order to deliver up to 1,200 MW of imported power from Quebec to the New England region. The filing amends Northern Pass’ application originally submitted in October 2010, with supplements filed in February 2011 and April 2011.
A representative for Northern Pass/Northeast Utilities (NYSE:NU), of which Northern Pass is a wholly owned subsidiary, could not be immediately reached for comment on Sept. 18.
Northern Pass recently proposed a new route for the project, partially underground and taking into consideration concerns about potential visual impacts and property rights, in the northernmost section of the project area in New Hampshire’s North Country.
The new proposed route includes 32.25 miles of new right-of-way, and partial underground construction within developed public transportation corridors, and follows a more easterly path than the original proposal submitted in 2010, the company said in late June.
The company has said that among benefits, the project is expected to reduce New Hampshire’s annual energy costs by $20m to $35m – regional savings of $200m to $300m – by displacing more expensive fossil fuel generation sources that would otherwise be needed to meet regional demand.
The project will also reduce regional carbon emissions by up to five million tons per year, and it is expected to generate about $28m in new property taxes annually.
NEPGA said in its comments that according to the amended application, the new proposed route is 187 miles long, with substantial reconfigurations to the north section of the proposed line. Northern Pass seeks to move the route as it crosses into the United States in a more easterly and southerly path through a less densely populated area of New Hampshire.
The company proposes to place two sections of the line underground including a 2,300-foot section under Route 3 in Pittsburgh, N.H., and 7.5 miles under state and town roads in Stewartstown and Clarksville, N.H., NEPGA added.
Since secure site control has not been shown nor known to be feasible, Northern Pass includes one “short alternative undergrounding routing option in the new portion of the North Section,” NEPGA said, adding that the alternative includes a 1,100-foot underground segment that would cross about 100 feet of private land and require the consent of the Connecticut Lakes Realty Trust and the New Hampshire Department of Resources and Economic Development.
NEPGA also noted that New Hampshire Gov. Maggie Hassan has said that the easement could not be used, a factor that is key in Northern Pass’ inability to not be able to continue its original route proposal.
The association charged that Northern Pass misrepresents the reduction in wholesale power prices, noting that Northern Pass asserts that “reducing regional wholesale power prices an estimated $206 to $327 million will be one of the prime benefits of the project.” That estimate is based on a study by Charles River Associates (CRA) prepared for Northern Pass in December 2010, but that report was limited in scope and solely addressed the project’s purported impact on New England electric prices, NEPGA said.
A study commissioned by NEPGA with PA Consulting Group in June 2012 reviewed the report, concluding that, “The striking result of the CRA analysis is not that wholesale prices were forced down, but rather the fact that the additional energy flowing over the Northern Pass Line, which represented approximately 5% of total [ISO New England (ISO-NE)] energy demand, reduced wholesale energy costs to New England load customers by just 2.8% in 2016 and only 3.2% in 2024.”
NEPGA also charged that Northern Pass misrepresents the reduction in carbon dioxide (CO2) emissions, saying that Northern Pass asserts the project will “reduce CO2 emissions by up to 5 million tons per year to assist in achieving the recently enhanced goals of the Regional Greenhouse Gas Initiative … and the New Hampshire Climate Action Plan.”
NEPGA added, “Although Northern Pass uses this estimate in its amended application, nowhere in the application does it provide substantiation or even a reference to how this estimate was calculated.”
The association also said that Northern Pass misrepresents the reduced dependence on natural gas, noting that Northern Pass asserts that reducing “New England’s heavy dependence on natural gas for power generation” is another key benefit of the project.
PA Consulting Group found that once the project would be operational, the increased imports into New England would result from reduced imports into Ontario, New York and over the New England Phase II tie. While “strictly true” regarding the reduction of gas use in New England, from a regional perspective, CRA assumes merely a shift in dependence on natural gas from New England to Ontario and New York, NEPGA added.
The association also claimed that Northern Pass misrepresents the project’s role in addressing New England’s reliability concerns.
During its 2011 session, the New Hampshire Legislature passed a bill to clarify that Northern Pass could not use eminent domain for the purpose of taking private land for the construction of its transmission line from Canada. A threshold question in the debate, NEPGA added, was whether the proposed project was one deemed to be necessary for system reliability to keep the lights on in New England. ISO-NE said the proposed project is an elective transmission upgrade, not a reliability transmission upgrade.
ISO-NE is working with stakeholders to address reliability concerns through market mechanisms including additional performance incentives, increased energy market flexibility and enhanced information-sharing between the electric and gas industries and ISO-NE. “The ‘solution’ of approving Northern [Pass’] proposed amended application for a presidential permit for its proposal to build a participant-funded, elective transmission line from Quebec to New Hampshire is not part of this policy discussion,” NEPGA added.
Among other things, NEPGA said that Northern Pass fails to discuss the significant reliability concerns to New England from the region relying upon a long-distance transmission line for a meaningful portion of the region’s supply, the association said, citing, for example, an Aug. 5 lightning strike on a power transmission corridor in Churchill Falls that caused an outage in Montreal affecting 400,000 Hydro Quebec customers.
In a Sept. 18 statement, NEPGA President Dan Dolan said: “New England’s generators continue to provide electricity supplies for consumers reliably and at competitive prices all while driving environmental emissions down. The thousands of people who efficiently operate the billions of dollars of assets invested in our region’s power facilities must be able to compete on a level playing field to ultimately drive the next wave of innovative investments and provide consumers the best prices for the electricity they demand.”