Appalachian Mountain Club Calls for New Visual Assessment, More Rigorous Analysis of Northern Pass Electric Transmission Project in Comments to U.S. Department of Energy

April 4, 2016

April 4, 2016

WASHINGTON, D.C. – In submitting its comments on the draft Environmental Impact Statement (DEIS) for the Northern Pass Transmission project (NPT) to the U.S. Department of Energy (DOE) on April 4, 2016, the Appalachian Mountain Club (AMC) strongly critiqued the DEIS Visual Impact Assessment. The organization said data used in many cases are now outdated and many of the assumptions used in its model are not valid, resulting in an underestimation of the visual impact on New Hampshire’s landscape from 1,100 new steel transmission towers up to 160 feet tall stretching over 132 miles.

The DEIS, issued by DOE last summer, with a supplement completed in November to analyze the new “preferred route” announced by NPT in August, was the subject of four hearings held last month in New Hampshire, at which the vast majority of hundreds of public comments were in opposition to the project as proposed and studied in the DEIS.

The comments state, “This Project has not been ruled grid essential by ISO-NE, is privately funded, and is structured to maximize very significant profits for the Project sponsors. The DEIS’s shorthand exclusion of reasonable alternatives undermines the importance of the NEPA [National Environmental Policy Act] process in protecting the public interest.”

AMC’s written comments call for the Final EIS to include a thorough analysis and comparison of all reasonable alternatives and their impacts. Reasonable alternative energy sources include energy conservation and alternative power generation sources such as wind, distributed solar, and grid-scale battery storage that in combination could potentially obviate the need for large-scale new transmission of hydropower from Quebec. Other alternatives include using a different international border crossing that would facilitate burial under I-91 in Vermont and provide a more direct route to the intended southern New England market with minimal environmental impacts; or burial along I-91 in Vermont to I-89 and I-93 in New Hampshire to Londonderry; or the use of other transmission projects, such as the New England Clean Power Link project in Vermont which currently is permitted, has open capacity, and would be 100 percent buried as current technology now permits.

Also, AMC calls on the DOE to stay this Presidential Permit process and instead first conduct a region-wide programmatic EIS on the region’s transmission and importation of Canadian power in light of Hydro-Quebec’s and the Province of Quebec’s long-term business plan (known as Plan Nord) to significantly increase production and exports of their hydropower to the Northeastern United States. It would take into account “the region’s energy policies and goals, the most efficient, least impacting means of importing Canadian power to meet any such need, and risks involved, the impact on US-based renewable energy resources, and how such projects could further increase the US trade deficit with Canada.”

In its comments, AMC also said:

DOE should define the “Purpose and Need” for action more broadly, allowing a reasonable range of alternatives to be identified and analyzed. According to AMC, “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.”

The Final EIS must include a rigorous assessment of the impacts of the proposed project and alternatives, including the environmental impact of hydropower generation and transmission in Canada, including the impacts of the damming of rivers and massive flooding required to generate power; excess carbon released by flooding of forested areas; and impact of cheap imported hydropower on the development of new domestic, renewable energy sources.

The full text of AMC’s comments on the DEIS can be found here: AMC Comments on draft Environmental Impact Statement (DEIS) for the Northern Pass Transmission project (NPT)

AMC is an intervenor in the permitting of the Northern Pass project and has opposed the project as proposed for more than five years.

Learn more about AMC’s position on Northern Pass at

Founded in 1876, the Appalachian Mountain Club (AMC) promotes the protection, enjoyment, and understanding of the mountains, forests, waters, and trails of America’s Northeast. AMC helps people of all ages and abilities to explore and develop a deep appreciation of the natural world. With chapters from Maine to Washington, D.C., guidebooks and maps, and unique lodges and huts, AMC helps people get outdoors on their own, with family and friends, and through activities close to home and beyond. AMC invites the public to support its conservation advocacy and research, youth programming, and care of 1,800 miles of trails. More information is available at

Search AMC Outdoors and Blogs

Search for:

Rob Burbank

Director of Media and Public Affairs
(603) 466-8155

Laura Hurley

Public Relations & Social Media Director
(617) 391-6621