The U.S. Department of Energy’s National Interest Electric Transmission Corridor Designation program is designed to improve electric transmission and reliability throughout the country. Transmission upgrades were proposed for ten regions across, including the New York-New England transmission corridor which links the two electric systems.
» Read BEAT’s comment, sent to the Department of Energy
Proposed project capacity: 345 kilovolts
Current system capacity: 115 kilovolts
Length of upgrade: Approximately a 60 mile stretch of transmission line.
Location: The transmission corridor right-of-way extension would likely impact 17 towns. These include Stephentown and Nassau, NY, and Lanesborough, Hinsdale, Windsor, Plainfield, Ashfield, Hancock, Dalton, Peru, Conway, Shelburne, Greenfield, Montague, Deerfield, Erving, and Northfield, MA.
Maximum possible corridor width: 1 mile
View interactive map showing the possible one mile corridor marked in purple
Potential maximum impacts: Berkshire Regional Planning Commission completed a study analyzing the impacts that a mile wide right-of-way could have on the environment and local communities. Within Berkshire County, they found that the proposed right-of-way would impact “905 buildings, ranging from just one in Peru to 323 in Lanesborough, and 832 parcels of land totaling 13,546.23 acres, including endangered species habitat.” In Franklin County Council of Governments’ study, they found impacts from the proposed right-of-way would include “4,000 acres of endangered species habitat; 5,800 acres of prime farmland soil and/or soild of statewide importance; 950 acres of aquifers; an 3,500 acres of permanently protected land … 99 buildings, structures and objects identified by the Massachusetts Historical Commission” and multiple significant farms.
Regional electric grid operators: ISO New England and New York ISO
The DOE’s NIETC proposal to update the New York-New England, if confirmed, would grant them a larger right-of-way (1 mile wide according to the initial DOE proposal) and eminent domain over households within the new borders. It is unclear how the larger right-of-way would be utilized for upgrades and whether the land would be clear cut or significantly disturbed otherwise. The DOE has maintained that the proposed NIETC boundaries will undergo revisions based on community feedback and internal research throughout the remaining phases of the process. Currently, the right-of-way for the transmission line from New York-New England varies from around 200 to 300 feet. Based on the DOE’s initial proposal, the right-of-way for the transmission line would extend to 1 mile wide, impacting properties and the environment along the 60 mile stretch of transmission line.
Transmission capacity upgrades are often necessary with increased electrification and clean energy sources increasing electric demand throughout New England. The environmental impact of transmission upgrades and clean energy infrastructure projects should remain as minimal as possible to preserve natural resources and critical habitat.
While electric transmission reliability and functionality will certainly be crucial throughout the clean energy transition in New England, electric demand in New England’s future will likely not surpass past demand. According to ISO-New England’s Electricity Use Site, the top ten peak electricity demand days in New England all occurred before 2014, with the majority taking place prior to 2007. Electric usage efficiency programs have lowered energy usage in the Northeast, and although electric demand is expected to increase in the future, peak demand will likely not surpass previously observed levels.
With the advent of smarter technology to improve energy efficiency in many industries, there is an opportunity to reduce non-essential electric usage in the future as electric demand increases amidst the climate crisis. Battery storage technology can identify times of elevated electric demand and shift non-essential electric usage to night time and other lower demand times as well, further reducing peak electric demand and the need for major transmission capacity upgrades. Also, virtual power plants (VPP) are emerging as a strategy that can help balance electric demand. VPPs utilize and manage the inactive electric potential of hundreds or thousands of households and businesses in a region to meet electric demand. VPPs not only reduce peak demand, but they may also help make electricity more affordable and reliable.
Public comments and opinions:
Eversource, the energy utility that operates the transmission lines, commented on the Department of Energy’s proposed NIETC designation for the New York-New England transmission line. They noted that the widening is far more than needed for the transmission project and is “concerning for the host communities.” Eversource even added that “the existing right-of-way in Massachusetts is several hundred feet wide, with sufficient scope and size to accommodate a new 345kV transmission project.” They also raised concern with the designation process and potential lack of community outreach, mentioning that community acceptance would be much more likely if the width of the proposed right-of-way was significantly decreased.
Proposal phases and future:
The DOE NIETC designation process involves several different opportunities for community, public, and organizational input. The process is currently entering Phase 3 (anticipated to begin Fall 2024). Phase 3 is the primary public engagement phase, where the DOE will host in-person and remote opportunities for public engagement and opinion. It is not clear yet what these comment sessions will look like. The DOE also intends to disseminate information to local news outlets during Phase 3. The main purpose of community engagement is to revise the proposed geographic boundaries of the NIETCs based on community needs and opinions. Any required environmental reviews under the National Environmental Policy Act (NEPA) will also be initiated at this phase.
The upcoming public comment and outreach phase beginning this fall will be essential for communities impacted by these proposed changes to voice their concerns and opinions. A growing number of stewardship and conservation groups have and are continuing to voice their concerns about NIETC to the Department of Energy’s Grid Deployment Office.
Public outreach is a critical component of any project with a potential impact to property owners and the environment. While the official public outreach phase for the Department of Energy begins this fall, comments, concerns, and suggestions can be directed to NIETC@hq.doe.gov at any time.
Resources:
National Interest Electric Transmission Corridor Designation Process
DOE Proposes National Interest Electric Transmission Corridor Designation Process
DOE Webinar Released at the Beginning of Phase 2
Berkshire Regional Planning Commission Study and comments
Franklin Regional Council of Governments (FRCOG) Study and comments
DOE Biden-Harris Administration Invests $2.2 Billion in the Nation’s Grid
ISO New England Key Grid and Market Statistics
For more information on the permitting process for electric transmission facilities, consult the Federal Energy Regulatory Commission page on permitting.
Comments of Berkshire Environmental Action Team
on the New York/New England NIETC Proposal
Berkshire Environmental Action Team (BEAT) appreciates this opportunity to provide feedback on the New York/New England NIETC Plan. We particularly welcome DOE’s efforts in reaching out for public comment on the Plan throughout the designation process. However, outreach to date has been limited to organizations in the eastern part of Massachusetts. It is critical that efforts be made to include environmental organizations in the western part of the state. The Berkshires is known for its natural beauty, which contributes to much of the local economy in the form of tourism; a report from 1Berkshire (Regional Economic Development Organization and Regional Tourism Council of Berkshire County), shows the total annual economic impact of visitor spending in the Berkshires alone at $960 million. A mile-wide corridor would cause great harm.
To expedite and streamline the process of expanding electric transmission, the Federal Power Act authorizes the Secretary of Energy to designate any geographic area as a National Interest Electric Transmission Corridor (NIETC). While the need to expand infrastructure capacity for renewable energy transmission and demand increases due to increased electrification is critical, the least impactful options on forests, endangered species, agricultural land, and residential areas must be prioritized. Although Massachusetts electricity prices are high, this is in large part due to the price of fracked gas, as it is now the marginal fuel. It is not electric transmission that sets the price, it is the result of the fact that the region is still overly reliant on externally produced, dirty, toxic fuel.
The current New York/New England NIETC plan designates a corridor one mile wide and 60 miles long, in spite of the fact that the transmission operator for this connection, Eversource, has stated that the existing right-of-way, which is only 200-300 feet wide, and currently 345kV, is adequate to transmission needs in that corridor. According to DOE, past NIETC proposals were turned down by the courts because “a process that designates vast swaths territory as NIETCs would cause delay and consume considerable resources, particularly of those swept up in a larger geographic footprint but outside of the path of likely transmission projects.” The New York to New England swath is a vast swath and should be narrowed to 300′
In the Massachusetts portion of the corridor, according to the Berkshire Regional Planning Commission (BRPC), the proposed mile-wide right-of-way would impact 15 towns, including Hancock, Lanesborough, Dalton, Hinsdale, Peru, Windsor, Plainfield, Ashfield, Conway, Shelburne, Greenfield, Montague, Deerfield, Erving, and Northfield. The corridor would affect 905 buildings and 832 parcels of land totaling 13,546.23 acres, including endangered species habitat in Berkshire County. In Franklin County Council of Governments’ (FRCOG) study, they found impacts from the proposed right-of-way would include “4,000 acres of endangered species habitat; 5,800 acres of prime farmland soil and/or soil of statewide importance; 950 acres of aquifers; and 3,500 acres of permanently protected land … 99 buildings, structures and objects identified by the Massachusetts Historical Commission” and multiple significant farms in Franklin County.
It is critical to ensure that Massachusetts’ forests are conserved and managed to optimize carbon sequestration and storage, and mitigate climate harms, as part of meeting the state’s aggressive climate goals (Forests as Climate Solutions Initiative). Cutting a wide swath through agricultural and undeveloped land for a transmission corridor would constitute a threat to meeting those climate goals.
ALTERNATIVES NEED TO BE INCLUDED IN DETERMINING NEED
DOE has indicated that the NIETC plan should accommodate future requirements for expanded electricity transmission in the region. However, the plan does not appear to take into account alternative methods of meeting those goals.
These include:
Alternative construction: Given the impacts of climate extremes and increases in severe weather events, there should be a thorough analysis of alternative construction, especially underground transmission lines. In the aftermath of Hurricane Helene, it was underground transmission lines that allowed Clemson University to resume operations just days later. They are now providing services as an on-campus hub to community members who are still without power and water.
Analysis of existing corridors. Eversource stated in their comments that a project of this voltage would be able to fit entirely within their existing corridor.
High voltage infrastructure does not require a wide corridor. As posted by the Texas PUC, voltage lines high as 765-kV shouldn’t need to be wider than 225 feet wide.
“The MISO 2024 Transmission Cost Estimation Guide has been referenced by ERCOT for evaluation of EHV options (500-kV or 765-kV) in recent studies. The guide differs from AEP’ s assumptions in certain ways, for example it assumes 225-feet for right-of-way width for 765-kV versus AEP’ s 200-foot standard, but it is a useful reference point for conceptual cost information.”
Using HVDC (high voltage direct current) corridors could be much narrower.
How is the proposal of a mile wide corridor (5,280 ft.) determined? At this
width there would be room for at least twenty-two 765 kV lines running in parallel, yet the proposal is to upgrade the existing 115 kV to 365 kV.
ANALYSIS OF DEMAND REDUCTION BEFORE DEFINING NEED:
Grid Enhancing Technologies (GETs), including dynamic line ratings, advanced power flow control, topology optimization, and advanced conductors, which enable increased electricity transmission along existing power lines. The Federal Energy Regulatory Commission issued Order 2023 in July of 2023, which requires transmission operators to consider advanced technologies for new interconnections. This should apply to the build-out of the New York/New England NIETC.
Virtual Power Plants (VPPs). According to a report from the Rocky Mountain Institute, expanding the use of VPPs has the potential for 61.9 gigawatts of capacity in the United States in 2030. Batteries would supply about 9.9 gigawatts; electric vehicles would contribute significantly more (17.3 gigawatts). But most of the capacity would be from homes and businesses (around 35 gigawatts) which would come from using the network to reduce electricity demand by adjusting thermostats, making use of home and vehicle batteries and grid scale battery installations that are being rapidly deployed across the state, among other measures.
Increased energy efficiency: According to the American Council for an Energy-Efficient Economy (ACEEE), between 2006 and 2021 utility efficiency programs decreased annual demand for electricity by roughly 220 TWh per year, accounting for almost one-third of projected demand growth. While electric transmission reliability and functionality will certainly be crucial throughout the clean energy transition in New England, electric demand in New England’s future will likely not surpass past demand. According to ISO-New England’s Electricity Use Site, the top ten peak electricity demand days in New England all occurred before 2014, with the majority taking place prior to 2007.
As climate change accelerates, we can expect more disruptive weather and more severe storms; transmission infrastructure is a potential key point of failure. The most common reason for grid outages is damage to transmission towers, poles, and wires. Rather than investing in more transmission infrastructure, reliability can be more consistently attained by investing in distributed energy and battery storage. Local storage and generation can ensure that no area loses power. This is a better path to resilience.
EARLY OUTREACH BY DOE TO IMPACTED COMMUNITIES NEEDED
We also support FRCOG’s recommendations for public outreach if this corridor proposal advances to Phase 3. Since BEAT is an environmental organization that works throughout the region, we are making recommendations below that cover all four counties affected by the proposed NIETC corridor.
It is imperative that DOE directly communicates with:
Local, regional and state officials for all municipalities within the proposed mile-wide corridor, including the Regional Planning Commissions and Councils of Governments and similar quasi-governmental regional organization
Environmental and natural resource groups from Berkshire, Hampshire and Franklin counties, MA and Rensselaer County, NY, including:
Rensselaer Environmental Coalition
Rensselaer County Conservation Alliance
Rensselaer Land Trust
Berkshire Natural Resource Council
Berkshire Environmental Action Team
Housatonic Valley Association
Tamarack Hollow
Trustees of Reservations
Hilltown Land Trust
Franklin County Land Trust
Hampshire Hampden Conservation District
Hoosic River Watershed Association
Westfield Wild and Scenic
Westfield River Watershed Association
Deerfield River Watershed Association
Connecticut River Conservancy
Business groups such as
Chambers of Commerce from all four counties
Tourism associations from all four counties
Community Involved in Sustaining Agriculture
Northeast Organic Farming Association
Local media that serves municipalities within the proposed corridor, including:
Eastwick Press
Berkshire Eagle
iBerkshires
Berkshire Edge
Greylock Glass
Country Journal
Daily Hampshire Gazette
Greenfield Recorder
WAMC Radio
New England Public Media Radio
News10 (ABC Albany affiliate)
WWLP-TV (NBC Springfield affiliate)
WGGB-TV (CBS / ABC / Fox Springfield affiliate)
Local cable-access TV stations and radio stations in affected communities
We also echo the public interaction suggestions of FRCOG:
A web-page on the DOE website with specific information about the New England / New York Corridor that includes contact information for accepting input from the public
In-person / virtual hybrid meetings for the public. There should be at least one meeting in each of four locations for Rensselaer County, in NY, Berkshire County, the upper Pioneer Valley region of Franklin County, and the Hilltowns region of western Franklin County and northwestern Hampshire County in MA. These should be fully accessible and of large enough capacity to accommodate a substantial number of attendees. Locations like Stephentown Town Hall, Berkshire Community College, Greenfield Community College and the Community House in Cummington, MA or Windsor Town Hall meet those requirements.
We also have a strong Environmental Justice policy in Massachusetts that requires translation and live interpretation for public announcements and proceedings. We expect that any announcements and proceedings for Massachusetts will follow similar protocols. Please see information and guidelines from our Department of Public Utilities.
Thank you in advance for your consideration and review of our input.
Respectfully submitted,
Jane Winn, Executive Director
Berkshire Environmental Action Team
Rosemary Wessel, Program Director
No Fracked Gas in Mass, A Program of Berkshire Environmental Action Team
John Prusinski, Project Assistant
No Fracked Gas in Mass, A Program of Berkshire Environmental Action Team
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Sent Oct 2, 2024
Cc’d:
“Melissa A Lavinson (EEA)” Melissa.A.Lavinson@mass.gov, rebecca.l.tepper@mass.gov, Paul Mark Paul.Mark@masenate.gov, Tricia Farley-Bouvier Tricia.Farley-Bouvier@mahouse.gov, john.barrett@mahouse.gov, Natalie Blais Natalie.blais@mahouse.gov, Susannah.Whipps@mahouse.gov, Jo.Comerford@masenate.gov, Lindsay Sabadosa lindsay.sabadosa@mahouse.gov, Smitty Pignatelli Smitty.Pignatelli@mahouse.gov, Jesse Lederman jesse_lederman@markey.senate.gov, Allyson_Huntoon@warren.senate.gov, Ashley_Coulombe@warren.senate.gov, zach.dupont@mail.house.gov, john.swords@mail.house.gov
McGovern – John.swords@mail.house.gov
Energy Policy
Neal – Zach Dupont energy policy
zach.dupont@mail.house.gov