FOR IMMEDIATE RELEASE
March 16, 2011
I am Kenneth Kimball, Director of Research for the Appalachian Mountain Club. The AMC appreciates the opportunity to comment on the DOE’s EIS scoping for Northern Pass’s Project. Tonight I will be brief and AMC will be submitting more detailed written comments.
First, some context:
The AMC is a non-profit organization of over 100,000 members and supporters in the Northeast including 10,000 members in New Hampshire. Many visit NH’s State Parks, the White Mountain National Forest, and the Appalachian National Scenic Trail on a regular basis to participate in outdoor recreational activities, thereby supporting NH’s tourism economy.
The AMC maintains over 108 miles of the Appalachian National Scenic Trail in the White Mountain National Forest in NH. The AT is a nationally recognized treasure and a unit of the National Park Service. This project would directly intersect with and negatively impact the Appalachian Trail.
This year the White Mountain National Forest will be celebrating the 100th Anniversary of the Weeks Act that created this Forest. The proposed Project would further scar 10 miles within the White Mountain National Forest.
When setting aside public lands for their outstanding ecological, visual and recreational resources the intent was not to resolve large scale infrastructure right of ways. Permitting the Project as proposed would be the most inappropriate way to celebrate the Centennial Anniversary of the Weeks Act.
Is the Application substantively complete for EIS review?
For the record the AMC believes the Application is substantively incomplete and this process should not have moved into the EIS scoping phase. The Application fails to describe the resources to be impacted, even though it acknowledges that Northern Pass collected considerable site specific resource data. Instead the Application guards that information in “off-limits” mode and in less than 4 pages provides only non-specific, generic topic listings.
The Application has an obligation to describe its proposed mitigation for Project Impacts. Similar to the dearth of information on resources impacted, proposed mitigation is entirely absent in the Application. Surely the Applicant did not believe its proposed project was without sufficient impact that mitigation was unnecessary.
With zero substantive environmental or mitigation information in the Application, though it exists, the public is strongly disadvantaged in this EIS scoping process.
The spatial boundaries for cumulative impact analyses required in an EIS should go beyond the site-specific impacts of the transmission corridor itself. The Application claims the project will provide “clean, low carbon hydroelectric power” from Canada. If such benefit is acknowledged in the EIS, it requires a cross the border analysis of the actual power source. For geographic parity the EIS should also describe the negative impacts of these hydroelectric dams on Canadian riverine ecosystems, including but not limited to major river and inter basin diversions, reservoir drawdowns, and the mobilization of mercury into the food chain.
The 2,179 mile Appalachian National Scenic Trail is cumulatively being degraded along its entire corridor from GA to ME by proposed energy projects including wind power and utility corridor projects. This Project would cumulatively add to the degradation of this unit of the National Park Service and its cumulative impact should be analyzed in the EIS.
(Note: Hawk Methany from ATC did a good job of listing all of the viewpoints along the AT the Project would be visible from, and than went further and listed all of the additional major peaks in NH it would be visible from.)
EIS Issues to be analyzed:
Alternatives to be Analyzed:
The EIS must examine all reasonable alternatives – be they in or out of the State of NH. Alternatives to be examined should but not necessarily be limited to the following:
The AMC requests that after this public scoping period, but before DOE initiates its EIS analysis, that DOE issue an EIS Scoping document for public review on the key elements it intendeds to analyze and how and which alternatives will be analyzed.