UPDATE: In October 2018, Central Maine Power Company (CMP) notified Maine regulators that they now intend to bury the proposed transmission line under the Kennebec Gorge. This new information addresses one flaw in the siting of the proposed project but does not address AMC’s other concerns. AMC remains opposed to the project as proposed.
Avangrid/Central Maine Power proposes to build a 145-mile above-ground High Voltage Direct Current (HVDC) transmission line from Beattie Township along the Canadian border to an interconnection point in Lewiston, Maine to transport HydroQuebec electric power from Quebec to Massachusetts. The proposed line would include 53.5 miles of a new 150-foot-wide cleared corridor through undeveloped forest. The remaining 91.5 miles would be co-located within existing transmission corridors but would entail widening of the corridor and/or the installation of taller towers in many areas.
The AMC has four primary concerns with this project:
AMC believes the proposed project’s permanent impacts to Maine can and must be avoided or minimized. We recognize that meeting the needs for a cleaner energy system for our region will require new infrastructure. However, proposed projects should look to the future and not use outmoded 20th-century technology. For example, a similar and competing HVDC project in Vermont (the New England Clean Power Link) is proposed to be 100% buried and is fully permitted, demonstrating that such an approach is both technically feasible and expeditious to permit. In addition, the Vermont project has a considerably larger mitigation package with actual nexus to the project’s impacts as compared to this proposed project. Compensatory mitigation should only be employed when impacts truly cannot be avoided or minimized, and mitigation amounts (whether land or dollars) should be determined relative to impacts created, not just the avoided cost of less-impactful options.
The new HVDC corridor would cross the Kennebec Gorge, one of Maine’s crown jewels due to its scenic value, whitewater paddling, fishing, and other river-based recreational values. It draws approximately 10,000 individual boaters each year in addition to many thousands who experience the Gorge through commercially guided raft and inflatable kayak (aka “ducky”) trips. The Gorge offers both thrilling Class IV-V whitewater and easier Class I and II whitewater for intermediate boaters. The latter occurs downstream of a high demand, mid-Gorge put-in access (Carry Brook) used by a broader spectrum of boaters. The transmission line would dominate the view from a popular downstream resting and lunch spot where boaters frequently spend over an hour.
The Kennebec Gorge is legislatively identified as a “Class AA river segment (‘best’). As described in the ‘Maine Rivers Study’, it has the highest composite river resource values in the state. The study described the Gorge as “an outstanding wilderness experience” and “one of the ten most primitive rivers in the entire northeast United States”, providing “one of the finest big water rafting and kayaking experiences in the eastern United States”. The values of the Gorge are recognized for special consideration under the Maine Rivers Act and LUPC P-RR (Recreational Resource) zoning. Immediately after crossing the Kennebec Gorge, it would cross Moxie Stream, another legislatively designated Class AA river.
Of further concern is that the proposed corridor width and transmission line alignment are designed to accommodate a second transmission line in the future, so this future incremental impact must be considered as well when looking at the proposed project. People come to this stretch of river to get away from civilization and development, not to be reminded of it. This above ground crossing should be avoided.
The NECEC as proposed would be located within an existing transmission corridor that crosses the Appalachian National Scenic Trail (AT) three times in less than a mile. However, the project would increase the scenic impact to the trail by widening the corridor and installing taller towers. Downplayed in the application and left unaddressed are the additional visual impacts to the AT that would occur from prominent AT viewpoints on Pleasant Pond Mountain and Moxie Bald Mountain as the line traverses the lowland between the two peaks.
Avangrid is proposing to relocate the AT to eliminate two of the crossings, which could potentially improve the trail experience if the move was to a suitable new corridor. However, Avangrid needs to collaborate directly with the local AT trail managers on this proposed relocation, not present a fait accompli solution that may or may not improve the overall quality of the trail experience in the stretch where the AT crossings occur. In addition, every effort should be made to avoid and minimize additional impacts to the important major summit viewpoints on this segment of the AT.
The visual impact on this relatively undeveloped landscape goes well beyond the Kennebec Gorge and Appalachian National Scenic National Trail. Numerous scenic waterbodies, streams, and cultural resources would also be visually impacted, including the Arnold Trail, Old Canada Road National Scenic Byway, Coburn Mountain, numerous remote and accessible ponds, Wyman Lake, Moxie Stream, the South Branch of the Moose River, and the Carabasset, Sandy, and mid-Kennebec rivers. Landscapes not dominated by human development and major industrial infrastructure are becoming rare, and this project as proposed cuts into the heart of one such area.
The new corridor has not been surveyed for rare plants or rare and exemplary natural communities, and surveys of existing corridors are out of date. The Maine Natural Areas Program has strongly recommended that these surveys be completed. Without this information, the impacts of the project cannot be fully understood. The application should not be considered by Maine DEP until this information is available.
The Western Maine Mountains region is part of the largest contiguous expanse of undeveloped forest in the eastern United States. It is an area of high conservation interest due to its ecological connectivity and climate change resilience. It lies within the most intact area of temperate forest in North America which has been recognized as the nation’s largest globally important bird area. It is also a critical ecological link between the forests of the Adirondacks, Vermont and New Hampshire to the west and northern Maine and Atlantic Canada to the north.
The new corridor would be one of the largest fragmenting features through this ecologically significant region, passing between the northern Boundary Mountains and the large block of conservation lands in the Attean/Moose River area, an area of particularly high ecological connectivity and resilience. It would clear a 150-foot wide corridor for over 53 miles (with the potential for future expansion to a 300-foot wide corridor), eliminate thousands of acres of existing and potential interior forest habitat, and create an impediment to the movement for many species. Unlike the temporary and shifting mosaic of impacts created by timber harvesting, the impact of the corridor would be essentially permanent.
Carving a new corridor through this ecologically significant landscape is unacceptable, unnecessary, and avoidable. The impact of the line could be avoided and minimized by co-location along the major logging road through the area and using modern burial technology, as has been shown to be feasible in other projects.
AMC strongly supports the Massachusetts Global Warming Solutions Act and its mandate to reduce the state’s carbon emissions by 50% by 2020 and 80% by 2050. AMC also supports Massachusetts Governor Baker’s participation in the U.S. Climate Alliance and its commitment to reducing greenhouse gas emission reductions consistent with the Paris Agreement. The NECEC would provide Quebec hydropower to Massachusetts in response to an RFP process intended to reduce global greenhouse gas emissions.
However, expert testimony provided to the Maine Public Utilities Commission has shown there is no clear information demonstrating that the NECEC power intended for Massachusetts will not simply be diverted from other destinations, like Ontario or New York, leaving those areas to fill the gap with other, as yet to be determined, sources of energy. Testimony to the New Hampshire Site Evaluation Committee documented the same concern with the recently-denied Northern Pass project. While the use of Canadian hydropower may reduce Massachusetts’s carbon footprint from an accounting perspective, it appears it would likely fail to reduce global atmospheric greenhouse gas emissions, which is what all states, provinces, and countries urgently must do, and what the Massachusetts Global Warming Solutions Act also must do, to live up to its name. The cost and impacts to Maine are far too high to build a project that doesn’t do the intended job. Both Maine and Massachusetts regulators must be certain that this project will reduce global greenhouse gas emissions at levels claimed before locking the State and ratepayers into it.
AMC strongly urges Massachusetts to match its longtime leadership in greenhouse gas reduction with leadership in regional landscape protection by looking beyond its own backyard to effectively avoid, minimize, and – as a last resort – mitigate the impacts of energy development when importing power in its efforts to reduce global GHG emissions. Exporting the societal and environmental impacts of power generation and transmission without giving them proper review, due diligence, or compensation is short-sighted and undermines the Commonwealth’s status as an environmental leader.