Consider the public interest finding you are charged to make in a manner that fully values the public trust and the resources it is intended to protect.
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- Northern Pass
My name is Jane Difley, and I am here this evening representing the Society for the Protection of NH Forests, where I serve as President/Forester.
Last week at the hearing in Meredith I summarized the Forest Society’s core concerns with the Northern Pass project as proposed. In Colebrook Will Abbott reviewed concerns we have about the project’s impacts on two of our larger forest reservations. Tonight I would like to address a basic concern before the SEC: how you determine whether this project serves the public interest.
The Forest Society protects land because of the public benefits such conservation provides. We hold conserved lands in public trust. It is our duty to defend these conserved lands from interests that would adversely affect the conservation values inherent in these lands. Similarly, the State holds land in public trust, and has a similar stewardship obligation for state parks, state forests and state wildlife conservation areas. Eversource is a private company with a fiduciary obligation to its shareholders. There is nothing inherently wrong with this, but the interests they bring to this table are very different from the interests of those who steward the public trust. When Mr. Quinlan says that he believes that the Northern Pass project as proposed is “balanced,” he is using a scale where money is the primary counterweight. What Eversource has proposed is a project that its customer, Hydro-Quebec, says that it is willing to pay to build.
The scale that the SEC must use to assess whether the project serves the public interest is very different. The counterweight on your scale is the public interest in protecting public lands, water resources, private lands conserved for public benefit, and the scenic landscapes that New Hampshire advertises around the globe to attract visitors to support our tourism economy. In a nutshell, the resources held in this public trust should not and cannot be for sale nor be made available for long term lease.
The state’s wetland resources are a critical piece of the water resources held in public trust. The state’s wetland protection law (RSA 482-A) requires an applicant for a wetland permit to demonstrate that it has studied alternatives that would avoid any adverse impacts "to the maximum extent practicable.” Only then can the applicant look to minimize or mitigate impacts.
The Northern Pass application asks the NH Department of Environmental Services to issue wetland permits for the disturbance of an astounding 142 acres of wetlands from Pittsburg to Deerfield. In the 27,000 pages of the NP application we see no evidence that the applicant has actually studied any alternative that would avoid any of the wetland impacts.
NP appears to suggest that they simply need to write a large check to the state’s wetland mitigation fund for the 142 acres of damages proposed, without considering any alternative that would significantly avoid these impacts. Our preliminary analysis suggests there are reasonable alternatives, that would allow NP to be built in a way that substantially reduces the wetland impacts. The point is that NP should be required to present information documenting that they have actually considered alternatives that would avoid the 142 acres of wetland impacts in the current application. The statute requires it, so the public interest requires it.
As you begin you review of the Northern Pass application, we ask that you consider the public interest finding you are charged to make in a manner that fully values the public trust and the resources it is intended to protect.
Thank you.