Durham Expends $90,000 to Date on Independent, Third-Party Analysis to Protect the Health of the Great Bay Estuary
On Friday, July 28, 2017, Durham Town Manager Todd Selig submitted a listing of concerns as part of pre-filed testimony that his community has with regard to the proposed Eversource Seacoast Reliability Project, currently being reviewed by the NH Site Evaluation Committee (SEC).
The $70 million transmission line would run 13 miles from Madbury to Portsmouth, a portion of which would be constructed in the Town of Durham, including through the campus of the University of New Hampshire, and under Little Bay to Newington.
The project is intended to bolster transmission infrastructure in a region with rising power demand. Many Durham residents have objected to the project, particularly the method of burying cables under Little Bay, arguing it will disturb sediment that could harm water quality.
“The Town of Durham wishes to go on record at this point in time as recommending that the SEC look carefully at all options that would have less impact and be less disruptive from an environmental and public interest perspective,” stated Selig.
Specifically, Durham prefers in declining order of preference the following options:
- To support what Durham understands to be the Town of Newington’s position that the Gosling Road Autotransformer Solution would be a far less impactful alternative to this Project;
- If the Transformer Alternative is not possible, then Eversource should use horizontal directional drilling (“HDD”) underneath Little Bay as a means of avoiding what could be significant impacts on Little Bay that would result from jet plowing and associated activities;
- If HDD is proven to be infeasible, then at a minimum the SEC should require Eversource to revise its plans, as per Durham’s experts’ testimony (see attached letter from Todd Selig to Eversource President William Quinlan dated 7/27/17 outlining concerns identified by GeoInsight-Woods Hole Group and Dr. Steve Jones of UNH), to adequately demonstrate that cable laying will occur under impact controls that will ensure adequate protection of the Little Bay ecosystem, and thus assure the residents of Durham and the Seacoast region that there will be no unreasonable adverse effects on water quality and the natural environment of Little Bay or that the impact on natural resources will be manageably limited in the Little Bay.
“The Town of Durham believes that absent consideration of these alternatives, this Project will have an unreasonable adverse effect on water quality and the natural environment, will unduly interfere with the orderly development of the region, and will not serve the public interest,” stated Selig.
Selig continued, “The residents of Durham consider Little Bay to be a priceless and fragile natural resource that must be protected against adverse impacts, especially when there are better alternatives available that could avoid those impacts.”
The Little Bay and the Great Bay Estuary as a whole provides critical wildlife habitat, nurseries for seafood production, buffering from coastal flooding, recreational enjoyment, and safe harbor for marine commerce such as lobster fishing and an emerging industry of oyster aquaculture
The Great Bay Estuary also serves as a magnet for tourism supporting the local economy and increases the value of nearby properties. This contributes to state and local tax revenues, as well as a uniquely special region within New Hampshire and Maine to live, work, and play. The Great Bay Estuary is part of the National Estuary Program, and it is recognized broadly as an exceptional natural area in need of focused study and careful protection.
Unfortunately, the Great Bay Estuary is showing signs of a failing ecosystem. The 2013 State of the Estuaries Report, published by the Piscataqua Region Estuaries Partnership, showed 12 of 16 environmental indicators with negative or cautionary trends.
“At a minimum, it is imperative that the Eversource Seacoast Reliability Project not contribute in any way toward further degradation of the Little Bay or the Great Bay Estuary,” stated Selig.
Durham resident Vivian Miller, who is leading local opposition to the project slated to move right past her home, agrees the health of the bay is paramount and is advocating for potentially less intrusive means of burying the cable that will not stir up sediment in the water body.
“The Durham community has consistently supported “Do no harm to the Bay.” The Bay’s future depends on how the SEC views the value of our precious Estuary and how they decide to protect it; particularly when there are alternatives,” said Miller. “Eversource either clearly does not understand the delicate nature of the Bay or just thinks no one is paying attention. “It’s important: Let’s make sure!” she continued.
The Gosling Road Transformer Alternative
Representatives from the Town of Durham have been in ongoing contact with representatives from the Town of Newington to discuss the Gosling Road Transformer Alternative. Durham’s understanding of Newington’s position is that the SRP as proposed to the SEC is not in the public interest when one examines all of the required factors. These factors include that the Transformer Alternative would impact less geography and fewer resources than the proposed Project and that the Transformer Alternative would be better from an economic growth perspective.
Durham supports Newington’s position on this issue. It is Mr. Selig’s understanding that UNH also supports this position.
“Both Durham and UNH believe that if there is a more viable way to provide the benefits to the electrical grid of the Project without having to construct a whole new transmission line through the Town, the campus and Little Bay that this would be far preferable,” Stated Selig.
The Horizontal Directional Drilling (HDD) Alternative
In the event that the SEC elects not to proceed with serious consideration of the Transformer Alternative, Durham believes the SEC should exercise its authority under RSA 162-H:10,V and hire an independent consultant to look into the option of HDD under Little Bay as a less impactful alternative to jet plowing, concrete mats, and significant associated activities that would be required to install the transmission cable in Little Bay.
The Town and its residents question whether Eversource has properly evaluated the HDD option. Eversource appears to have completed a limited review of HDD, saying it will take too much time, is too expensive, has environmental risks (from slurry and bore fracking) and that it would create a high level of disturbance for residences (for the layout area) and roads.
Eversource provided generalized information (e.g., marketing brochures of HDD companies, pictures of other projects, etc.) about HDD, with their pre-filed testimony to the SEC and responses to data and record requests, but in the Town’s view it has not provided adequate and specific information to support the reasons it provides for not doing HDD.
The Town of Durham believes that Eversource did not complete an adequate analysis, such as a subsurface geotechnical investigation, to demonstrate to the public or the SEC why HDD is infeasible, or if it is in fact feasible, whether it is less impactful ecologically.
The fact that HDD could be technically challenging should not trump the negative impact of the proposed plan to Little Bay. More specifically, such an expert should look at Eversource’s costs in the context of other public costs (i.e. costs of cleaning Durham’s and other towns’ point source wastewater discharge to comply with stricter EPA requirements, costs of cleaning Little Bay over prior decades, costs of reclaiming oyster beds by reseeding done over last 20 years, and other relevant public costs expended to revitalize the Bay).
Durham also submits that it is important for an independent, expert analysis to be done that would weigh these issues, along with the environmental risks of jet plowing and associated underwater cable installation activities raised in the Joint Little Bay Testimony, as compared with HDD. Without a clear independent comparison of the risks of jet plowing versus the risks of HDD, the Town believes that there are major uncertainties that make the project risky to the Little Bay.
“We believe that the SEC, the affected towns and their residents, and the region as whole would benefit from such an independent analysis of whether HDD is a better alternative. Without such an independent review of HDD as compared with the current jet plowing proposal, Town residents feel they are being asked to assume significant risks without the benefit of a thoughtful and thorough analysis of what appears to be a viable and preferable alternative,” stated Selig.
Unitil used HDD in a different part of the same watershed fairly recently to place a natural gas line under the Piscataqua River as part of the Spaulding Turnpike widening project.
Durham’s Position on the SRP at this Time
“At this time, without having seen the agency reports that are due on August 1, 2017 and without having seen a thorough analysis of the Transformer Alternative and the HDD alternative, Durham believes that this Project as currently proposed will have an unreasonable adverse effect on water quality and the natural environment, will unduly interfere with the orderly development of the region, and will not serve the public interest,” said Selig.
To date, Durham has expended approximately $90,000 on independent, third-party expert analysis relative to the environmental impact the proposed SRP may have relative to Little Bay and the Great Bay Estuary.
State agencies are required to issue final permits and conditions to the SEC relative to the project, if any, by August 1, 2017.
To learn more about the Eversource SRP, go to https://www.eversource.com/Content/nh/about/major-projects-infrastructure/new-ham.
Letter to William Quinlan on Eversource SRP 072717