October 03, 2012PINKHAM NOTCH — The Northern Pass Transmission (NPT) line project as now proposed would have a significant visual impact on a number of resources of state and national significance, according to an analysis filed on Sept. 25 with the federal Department of Energy (DOE) by the nonprofit Appalachian Mountain Club (AMC) as an addendum to its earlier scoping comments.
DOE is one of three agencies — two federal and one state — that must rule on permits that will be sought by NPT and the project applicant. The AMC opposes the proposed NPT project.
Visual impacts could severely affect the state's natural landscape in its northern and central sections, which AMC describes as "a keystone for N.H.'s tourism economy."
AMC reported: "The N.H. tourism segment associated with high-quality open space is estimated to have a direct and indirect value in excess of $3 billion dollars, involving over 64,000 jobs."
Its analysis also indicates that should the existing 120-mile-long transmission corridor be widened up to 410 feet and additional towers erected of up to 135 feet, then some 95,000 acres in New Hampshire, including 3,000 acres in the WMNF, six scenic outlooks, and a trail crossing along the Appalachian Trail plus four rivers and four scenic and cultural Byways, could also be impacted.
Since NPT has not yet identified a 40-mile ROW through northern Coös County where no right-of-way (ROW) now exists, the AMC did not document the visual impacts for the proposed project's northernmost segment south of the Canadian border.
Nor did AMC include the segment starting at the Groveton substation through Lancaster to Whitefield.
"The revised Application may contain a rerouting of the northern 40 miles which in turn could alter the route between Groveton and Whitefield," the AMC report points out. "The study area for this report is limited to the corridor from Whitefield south: when the Applicant identifies the placement of the corridor north of Whitefield, this assessment will be expanded to include that region."
AMC concludes: "Considering all the towns south of Whitefield within the 10-mile buffer area, nearly 95,000 acres are exposed to at least one tower; over 32,000 acres are exposed to 20 or more towers, and over 40,000 acres are exposed to between 6 and 20 towers. Many of these acres represent a field or other open space that a person walking, snowshoeing, snowmobiling, hunting or other outdoor activity may be visually exposed to the Project."
AMC said it "used US Forest Service accepted principles and methods for scenery impact analysis to prescribe a thorough and rational approach on how the full range and scope of scenic impacts created by the Northern Pass should be accomplished."
Co-author Ken Kimball, Ph.D., AMC's Director of Research, noted: "That DOE had advanced this application to the public scoping phase without any visual impact analysis for public review is highly unusual for an environmental review process and, to date, has left this data void for the public to fill. This is very unfair to the public," he said. "It is paramount that the permit reviewing agencies now guarantee that a thorough and honest assessment of the visual impacts of this proposal be conducted and used in the decision-making process."
AMC cartographer Larry Garland co-authored the study.
AMC points out that its models used conservative parameters, assuming tower heights of only 90 feet, for example, although in some locations they could be as high as 135 feet. Screening of views by the forest was also considered.
AMC identified 14 Priority 1 and nine Priority 2 locations that it believes call for visual simulation photographs using appropriate conditions and seasons, tower heights, and corridor widths.
Priority 1 locations, most located in Grafton County, include: the Appalachian Trail (AT) on Kinsman Ridge Trail at the NP crossing and also below summit of Mt. Wolf; South Kinsman Mtn.; Turtletown Pond in Concord; I-93 crossing at milepost 98.8 in Woodstock; the AT on Benton Trail, .15 mile north of Mt. Moosilauke summit; Pawtuckaway State Park firetower; Rte. 302 in Bethlehem at NP crossing; and locations on I-93.
None are located in Coös County. This could change once the NPT's first 40 miles is identified and the route from Groveton south to Whitefield is added
The AMC notes that the presence of towers would also have a cumulative effect. "A hiker traversing this section of the AT would be visually impacted at 6 prominent viewpoints and one trail crossing. … Visitors accessing the Franconia Notch region in the WMNF using Interstate I-93 would incur six crossings of NP and eight additional exposures of close proximity."
There is no need to change the study's conclusions because of NP's recent announcement of lower towers in an existing 10-mile ROW corridor through the WMNF, most within sight of I-93, Kimball said.
"Northern Pass's release last week of a plan to replace approximately 50-foot-high wooden towers with 85-foot-high steel monopole towers and additional 85-foot-high steel lattice towers in the section proposed to run through the WMNF would not alter in any practical way the results of the AMC study," Kimball said.
AMC field-checked its analysis with site visits to nearly 90 of 140 vantage points that were identified in the known corridor to have scenic viewpoints of state or national significance.
"It is clear from the study that the proposed NPT corridor is of sufficient size to be an incongruous industrial intrusion on the natural appearance of the surrounding landscape," Kimball said in a press release.
Although not part of its application materials to DOE, in 2011 Northern Pass posted 12 visual simulation photographs prepared by LandWorks of Middlebury, Vt., on its website, noting that they were "prepared to help inform community officials and members of the public as to what the project might look like."
"Unfortunately," Kimball charged, "their simulated views appear to have been chosen without a strong rationale and did not take into account many viewpoints of state and national significance within the project area. Furthermore, the timing and locations of the photo simulations on Northern Pass's website are problematic. For example, one of the photos is taken on a late October afternoon when the project corridor is within the shadow line at dusk – hardly representative relative to basic visual assessment protocol, if informing the public was their purpose," Kimball said.
David Raphael, the principal and owner of LandWorks who earned a Master of Landscape Architecture (MLA) at Harvard's Graduate School of Design, strongly objects the criticism that Dr. Kimball has leveled at his 12 visual simulations. "As NPT's engineers develop designs for the line, they are working with LandWorks to determine how the NPT will actually fit within the N. H. landscape," Raphael said in a prepared statement. "NPT has also been criticized for the lack of any comprehensive visual impact analysis or assessment (VIA). The fact is that a VIA is underway and when fully developed it will be presented. VIAs," Raphael explained, "are not typically initiated and completed until the route and structure design options are fully developed. It is unfortunate that some have criticized the review and analysis process conducted by Northern Pass without sufficient information or perhaps a complete understanding of the visual assessment process."
Raphael pointed out in a Thursday afternoon phone call that he has a neutral stance toward this proposed project. It is LandWorks' intention to put the line in context, section by section, he said. For example, there could be some sections, Raphael explained, in which the use of non-specular (non-reflective) cable could be recommended as a way to reduce its visual impact.
Northern Pass, LLC, a venture of Northeast Utilities, the parent company of Public Service of New Hampshire (PSNH), is in the process of seeking approval to construct an above ground, 350 kV high-voltage Direct Current power transmission line through New Hampshire to carry 1,200 megawatts of power generated by Canada's Hydro-Quebec to a converter station in Franklin. The DC power would then be converted to AC to run on an additional 40-mile line to connect to a network power distribution grid in Deerfield for distribution onto the New England power grid.
AMC's visual impact assessment study was funded in part by the New Hampshire Charitable Foundation (NHCF) that has taken no position on the Northern Pass project.
A link to AMC's visual assessment study is online at: www.outdoors.org/northernpass.