“Considering all the towns south of Whitefield within the 10-mile buffer area, nearly 95,000 acres are exposed to at least one tower.”

Previewed in Easton at the White Mountain National Forest ~ Northern Pass meeting on Sunday, the Appalachian Mountain Club’s Visual Impact Assessment was filed as an additional 38-page scoping comment with the DOE today. It necessarily refers only to the known proposed 120-mile route from Whitefield south.

In view of the project developer’s failure to include any information containing visual impacts in its Presidential Permit application, the AMC calls for the DOE to conduct a full scale visual assessment and offers its recommendations concerning such a study:

“In our [earlier] comments we specifically highlighted the need for a quality visual assessment. In the absence of basic visual impact information in the Northern Pass Application of October 2010 and none since, the AMC undertook a Northern Pass visual impact assessment based on best available information. We hereby submit for the record as an addendum to our June 14, 2011 Scoping Document comments our visual impact assessment and recommendations contained within. Our study includes both a reasonable approximation of important resources and viewpoints that would be visual impacted and cumulative impacts at different scales. We also provide specific recommendations on how the Department of Energy should conduct its final visual assessment once site-specific information for the northern corridor, reasonable alternatives, tower heights and corridors widths are made available. The information provided is based only on the southernmost 120 miles of the proposed corridor. Absent as of this filing date from the Applicant is a defined corridor for the northernmost component. AMC continues to be baffled as to how DOE accepted the Application as sufficiently complete to advance this project to the public scoping phase of a formal environmental review absent: i.) any specific route for almost one-third of the corridor (aka northern route), ii) sufficient basic environmental data, or iii) any reasonable alternatives proposals. This is a very piecemeal and confusing approach for fair and reasonable review by the public for a project Application of this magnitude. This addendum to our earlier scoping document supplements and does not replace our previous comments. These comments should be included under the current scoping categories of: tourism, cumulative effects, quality of life, viewshed/scenery, recreation and Forest Service Lands.”

While the AMC’s Assessment is not meant to be an in-depth visual analysis but rather to call for one and to suggest its parameters, it does offer visual impact data for the 120-mile known proposed route to legitimate its request, e.g.,

“Overall Impact to New Hampshire from Whitefield to Deerfield

“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 twenty 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.”

The AMC concludes that:

“The application that was filed for the Northern Pass in October 2010 contained no information related to visual impacts of this project nor has any been provided to date. It was unacceptable for an Application to be submitted without fundamental base information on such an important impact for a project of this magnitude and unfair to the public. The DOE EIS should conduct in depth analyses and consideration of the potential impacts to the most valuable scenic resources that contribute significantly to a $3 billion tourist industry. Based on the time since the Application was submitted and the lack of visual impact data publicly available to date, it would be unreasonable for the Application processes to now use an excuse that a need exists for a timely decision to override how and when appropriate visual analysis should be done in the field. The general public needs and deserves to have thorough, complete, and documented information on visual impacts available before any permit decision is made.

“The set of 12 visual simulations prepared by LandWorks of Middlebury, VT for Northern Pass are faulty and problematic. The rationale for selecting these 12 observation points is not documented. It does notappear that these points are well matched to locations of concern or scenic importance, nor that NP has determined where the most serious impacts will occur. The choice of locations, the time of day, sky conditions, and the perspective of the viewer do not properly or adequately reflect the experience of the viewer when traveling through the region.

“The 10-mile section of the Northern Pass that crosses the White Mountain National Forest has been studied three times before for infrastructure development since the 1970s. In all cases these projects failed to pass muster due in part to the impacts that would have occurred to this designated resource.

“The application review processes must build on this study using site-specific route, tower type, tower height, corridor width, and higher resolution land cover data to thoroughly study scenic impacts.


•Visual impacts must be systematically selected and evaluated for all viewpoints of high public concern. We outline a reasonable strategy for such an approach.

•Impacts must be evaluated both as important viewpoints and for cumulative impacts on specific resources, be they a National Scenic trail, a National Forest, the State and by individual towns as we illustrate in this study.

•Impacts must be evaluated against accepted Scenic Integrity Objectives

• Visual assessments must consider how scenic impacts will influence property values and quality of life.”

This is a very important study authored by an organization with authority, expertise, and credibility. You will hear a lot more about it.