Dear Secretary Granholm:
I write to express my concerns and request an agency review of the issuance of a Presidential permit, as well as the accompanying Environmental Assessment (EA)/Finding of No Significant Impact (FONSI) by the Department of Energy (DOE) to Central Maine Power (CMP) for the New England Clean Energy Connect (NECEC) project. Given the anticipated impacts this new transmission line will have on Maine's forest and wetland ecosystems, as well as on the communities along the route, it is troubling that the permit was granted by the previous Administration without a more thorough National Environmental Policy Act (NEPA) review and robust public participation consistent with the process followed by the Department for similar projects in New England.
The NECEC project consists of a transmission line that is approximately 145 miles long - a third of which would require the placement of new transmission lines through undeveloped forests in Maine's North Woods, fragmenting the largest contiguous temperate forest in North America. According to CMP's Section 404 Clean Water Act application to the U.S. Army Corps of Engineers, the company reports that the construction of new transmission lines will impact an estimated 263 wetlands and 115 streams. In fact, CMP made clear that the project will "unavoidably result in permanent and temporary wetland fill" from the establishment of access road and structure preparation areas, travel lanes for vegetation clearing, conductor puller and tensioner locations, guard structures, and guy anchors. In addition, it is expected that forest in wetlands and vernal pool habitat will be removed to adhere to clearance specifications for overhead transmission lines. The areas in which these activities will occur are in essential wildlife habitat for several endangered species and could adversely impact recreation and tourism benefits to local economies.
With the high level of public interest in this project given the potential environmental and economic impacts to communities throughout northern Maine, Bruce J. Walker, Assistant Secretary at the Office of Electricity sent U.S. Senator Susan Collins a November 8, 2019 letter stating, "In the case of NECEC, DOE intends to make a draft EA available for a 30-day public comment period to provide more time for input by your concerned constituents and local experts." You can therefore understand the frustration my constituents and I share that DOE reneged their previous commitment and instead issued a final EA in conjunction with the Presidential permit on January 14, 2021 without any sort of opportunity for public engagement.
It is important to note that the federal permitting process of similarly scaled regional projects, such as the Northern Pass Transmission Line in New Hampshire and the New England Clean Power Link project in Vermont, afforded impacted communities several opportunities to participate in public hearings with DOE as part of the agency's NEPA review. As with the NECEC, both of these proposed projects involved cross-border transmission lines from Canada that extended over one hundred miles into their respective states. For the Northern Pass Transmission Line in New Hampshire, DOE conducted four public hearings and in Vermont, DOE organized two public hearings for the Clean Power Link project.
The Presidential permit for the NECEC project makes clear that it can be "modified or revoked by the President of the United States without notice, or by DOE after public notice, and may be amended by DOE after proper application thereto." In an effort to ensure a transparent and thorough permitting process, I urge you to reevaluate the issuance of the Presidential permit and provide Mainers with the opportunity to engage with your agency through a public comment process that is merited for the significance of this project.
Sincerely.