To the editor,
In his Sep. 19 letter about the scenic impact of the Northern Pass Transmission project, Eversource Spokesperson Martin Murry claims “significant misunderstanding or misrepresentation” of the project. As proof, he cites the Federal Final Environmental Impact Statement for Northern Pass. He was replying to a Sep. 12 letter that had the suggestion that “outside interests — particularly from corporations — are influencing local policies.” So let’s look at the facts.
In New Hampshire, the Site Evaluation Committee has the responsibility to evaluate new facilities in the public’s best interest, represented by the Counsel for the Public.
Interestingly, the same consultant, T. J. Boyle of Vermont, was contracted to evaluate the potential Northern Pass visual impacts both for the 1) Department of Energy residential permit needed to connect an electric transmission line across the U.S. border with Canada, and 2) N.H. SEC certificate.
Here is what TJ Boyle had to say in the pre-filed and supplemental testimony to the Counsel for the Public, about the difference between the Federal and New Hampshire processes:
1) DOE presidential permit analysis:
• Is at a landscape planning scale, which was more appropriate for the national security concerns associated with the presidential permit that DOE is considering.
• Evaluates seven alternative proposals.
• Does not consider site-level mitigation.
• Does not have any procedures or guidelines for evaluating visual impacts.
2) N.H. SEC Certificate analysis:
• Looks the aesthetic effects of specific siting and design details.
• Identifies effective measures to avoid, minimize or mitigate adverse effects on aesthetics.
• Does not consider alternatives.
• Has explicit guidance on how to conduct a visual assessment.
What TJ Boyle found in his evaluation for Counsel for the Public, in the interest of the New Hampshire public:
a) Significant errors in Northern Pass approach to identifying scenic resources, which in itself, renders the Northern Pass visual analysis unreliable for decision-making.
b) Failure to consider visibility based on bare ground conditions.
c) Unsupported introduction of new evaluation factors.
d) Photo simulations that do not meet SEC or professional standards.
e) Undervaluation of the expectation of the typical viewer.
f) Undervaluation of the effect on future use and enjoyment of scenic resources.
Their summary, T.J. Boyle’s independent review for CFP of the Northern Pass visual analysis of scenic resources found, and demonstrated, that:
1) Scenic resources were not adequately identified.
2) Visual impacts were much greater than Northern Pass’s DeWan & Associates recognized.
3) Many of those visual impact clearly were unreasonable.
So, who is “significantly misunderstanding or misrepresenting” the New Hampshire relevant facts?
Berlin and Deerfield