By Kris Pastoriza
Over the past five years Eversource has replaced a large portion of its 345 kV and 115kV transmission lines. Most have been elective transmission ‘upgrades’ justified by ‘Asset Condition’; age or damage as determined by Eversource. Landowners along these lines probably thought these new lines had been deemed necessary for system reliability by ISO-NE (Independent System Operators, New England) or the NH Public Utilities Commission.
On Eversource’s 115kV ROWs in New Hampshire, existing wood structures have been replaced with steel structures, generally 15’+ taller, and 50% wider. Conductors have been replaced with larger, heavier lines to carry more power. Regular ground-wire has been replaced with heavier optical ground wire (OPGW), though fiber-optic is not permitted in the terms of most of the ROW easements. Eversource has built substantial roads on the ROWs, which it claims are necessary for the heavy equipment required for this new construction. Eversource is leaving these roads in place.
In early May, 2023, New Hampshire landowners encumbered by Eversource’s X-178 line received notification that Eversource had “identified the need to replace the wood structures and conductor (wire)” on the X-178 line, meaning that this was yet another ‘Asset Condition’ project. This new line would connect the larger, replaced Coos Loop lines with the larger, replaced 115kV lines now running from Beebe River (Campton) to Scobie Pond; all Eversource Asset Condition projects.
The X-178 line goes through White Mountain National Forest, through Bog Pond, and crosses the Appalachian Trail and the Reel Brook Trail, both listed on the National Register of Historic Places. This is the route Northern Pass abandoned because of the possibility that the Forest Service would deny them a Special Use Permit, because of the extensive visual impact and environmental damage the lines would have caused to this fragile and unique area.
In February, 2023, the New England States Committee on Electricity (NESCOE) raised the problem of Asset Condition projects:
“In March 2016, when ISO-NE first began tracking Asset Condition Projects…there were $58 million in Asset Condition Projects planned or under construction. Since that time, over $2.787 billion of Asset Condition Projects have been placed in service, and $3.255 billion more are proposed, planned, or under construction. By way of comparison, ISO-NE-identified reliability projects currently proposed,
planned, or under construction are estimated at $1.317 billion
Yet, the costs of Asset Condition Projects are nonetheless allocated to consumers across New England in the same way as the reliability projects that ISO-NE selects.”
On May 15, 2023, Synapse Energy Systems wrote to ISO-NE and New England Transmission Operators (NETOs):
“Synapse is concerned that the lack of regulatory oversight may be creating a perverse incentive
for NETOs [New England Transmission Operators] to pursue asset condition spending disproportionately, unnecessarily, and/or exorbitantly. We understand there are few strings attached to the approval and rate-basing of asset condition projects, and NETOs earn a guaranteed rate of return [11.68%] on these investments. The ostensible lack of cost review and containment measures also raises questions over whether NETOs are prudently incurring these investments.”
Eversource has refused to provide documentation of pole damage to support its claim that “many” (how many?) of the X-178 structures are damaged (how damaged?)
Eversource has refused to provide a life-cycle cost or CO2 assessment of wood vs. steel structures.
Eversource failed to provide data showing that the X-178 line, and the other Asset Condition former lines, failed to meet the reasonable needs of service to the public.
The NH PUC/DOE approved all Eversource’s public lands/water crossing applications associated with Eversource’s Asset Condition projects without requiring Eversource to provide the above information.
The NH PUC/DOE approved all Eversource’s public lands/water crossing applications for which the ROW easement deeds do not include permission for fiber optic.
Eversource’s New Hampshire overhead transmission project expenses in the March 2023 Asset Condition list (2017-2023 ) add up to approximately $900,000,000. Presumably its (154) Connecticut Asset Condition projects and (74) Massachusetts Asset Condition projects are also being paid for by New Hampshire Eversource customers.
The NH Public Utilities Commission must place the proposed construction of a new X-178 line on hold, and determine if Eversource’s construction of these new lines created unnecessary costs to Eversource’s New Hampshire ratepayers.
Contact the NH Public Utilities Commission or the Consumer Advocate for questions or concerns about Eversource proposed or completed construction on your land, or how Asset Condition projects will affect your bill from Eversource:
clerksoffice@puc.nh.gov
Kris Pastoriza, Easton, NH krispastoriza@gmail.com