AMC submits testimony to SEC against Northern Pass

Hearings to begin this spring

While AMC staffers have until a scheduled March 15 deadline to submit final evidence to the New Hampshire Site Evaluation Committee (SEC) against Northern Pass—the controversial 192-mile, high-voltage transmission project proposed to cut through the center of New Hampshire’s White Mountains—the hearing process may be delayed by a month or more.

The AMC is one of a few key organizational players, including the Society for the Protection of New Hampshire Forests (SPNHF), among scores of interveners including individual property owners and municipalities opposing the proposed energy transmission project.  The Club sought funding from chapters to support its efforts against the project as proposed, and the NH and Boston Chapters helped finance the testimony of Harry Dodson, of Dodson and Flinker, assessing the aesthetic impact of the project, which the AMC has made the focus of its opposition for almost six years, when Northern Pass was first proposed.

“Similar proposed projects in the Northeast have been permitted in less than two years using 100 percent newer burial technology,” AMC Vice President for Conservation Susan Arnold writes.

After entering Pittsburg, NH from Canada, Northern Pass will traverse above ground north of the Kilkenny Ridge and through Whitefield to Bethlehem before passing underground for 52 miles through the White Mountain National Forest and under the Appalachian Trail thereafter traveling overhead again through the Lakes Region en route to Deerfield through Concord and the Merrimack Valley.

A final decision regarding Northern Pass is expected from the SEC in September 2017, though the process could be further extended.  All testimony currently submitted to the SEC can be accessed at

Harry Dodson

Dodson and Flinker, Inc.

Ashfield, MA

[Northern Pass] will have an unreasonable adverse effect on aesthetics…Its overall visual impact is not comparable to any other single infrastructure project existing in the State today…[Dodson and Flinker] identified 57 additional viewpoints where the proposed transmission corridor would be visible. These are scenic resources as defined by SEC rules.

            [Northern Pass’s Visual Impact Assessment (VIA)] fails to address the unique and fragile aesthetic character of undeveloped lands and pastoral farm landscapes of New Hampshire, and discounts the potential of relatively distant changes in the landscape to exacerbate visual impacts.

The project’s scope and scale are so extensive that available mitigation measures will be ineffective in achieving a significant reduction in aesthetic impacts. Burial of the project offers the only means of significantly reducing the project’s unreasonable adverse aesthetic impacts.

Dr. Ken Kimball and Larry Garland

AMC Director of Research and AMC Staff Cartographer

Pinkham Notch, Gorham, NH

            AMC is concerned about energy infrastructure’s sprawl impinging on New Hampshire’s diminishing open spaces and is a strong advocate of requiring best practical measures to minimize project impacts.

            [Northern Pass’s] ultimate conclusions are based upon a systematic under-inclusion of significant scenic resources and the injection of unarticulated, subjective valuations of scenic resources…AMC identified 82 scenic resources…within three miles of [Northern Pass] that were not evaluated for scenic significance.

            [Northern Pass] did not conduct any form of public outreach to measure what expectations and reactions the public – residents, second home owners, tourists and recreationists – would have for their experiences if they encountered this proposed Project on New Hampshire’s landscape.

Public and town officials’ testimony in this proceeding…document overwhelming dissatisfaction with the proposed Project…78 percent expressed opposition to the project as proposed…53 percent specifically articulated their opposition was based, in part or whole, on potential aesthetics (visual) impacts.

Dr. Dave Publicover

AMC Assistant Research Director and Senior Staff Scientist

Pinkham Notch, Gorham, NH

            [Northern Pass] would have a significant adverse effect on an exemplary occurrence of the rare Northern Hardwood Seepage Forest Natural Community.  This occurrence is one of only two in the state…Given its size, condition and the presence of eight rare plant species, this occurrence must be considered a very significant component of the state’s natural biodiversity.  [Northern Pass] would destroy one-quarter of this community occurrence through corridor clearing and degrade an additional 20 percent to 40 percent of the occurrence through edge effects.

            [Northern Pass] would [also] impact…three potentially exemplary rare natural community occurrences, 33 occurrences of four other rare (S3) natural communities and 20 separate populations of nine rare plant species…[and] would be the largest fragmenting feature in the greatest expanse of undeveloped forest in New Hampshire outside of the White Mountain National Forest.

            [Northern Pass] has failed to take best practical measures to avoid, minimize and mitigate these impacts.  In particular, the applicant has failed to utilize an alternate route that would avoid these impacts in their entirety.

Chris Thayer

AMC Director of North Country Programs and Outreach

AMC Highland Center, Crawford Notch, Bretton Woods, NH

            Tourism and four-season outdoor recreation are important industries in the economy of New Hampshire, and are especially significant to the small communities that count natural scenic beauty as a critical asset to their economic survival…travel and tourism is NH’s second largest industry in terms of jobs supported by dollars from out of state…

            In 2002, [New Hampshire Division of Travel and Tourism] initiated a third party study of the state’s tourism image…study respondents ranked New Hampshire as number one among New England States in: Fall foliage, scenery/natural beauty, access to mountains, lakes and rivers, quaint towns and villages, parks and forests and outdoor sports activities.

Risk Management Values Clarification

Enhancing the metaphoric transfer of learning in wilderness expeditions