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To: Jackson, Ryan[jackson.ryan@epa.gov] From: Todd W. Lavin Sent: Wed 10/11/2017 6:05:30 PM Subject: Response letter NPT Response to USACI Letter (10.07.2017).pdf Ryan, Our response to letter EPA Region 1 sent to US Army Corps of Engineers Todd Lavin Eversource Energy 901 F Street, NW, Ste 602 Washington, DC 20004 This electronic message contains information from Eversource Energy or its affiliates that may be confidential, proprietary or otherwise protected from disclosure. The information is intended to be used solely by the recipient(s) named. Any views or opinions expressed in this message are not necessarily those of Eversource Energy or its affiliates. Any disclosure, copying or distribution of this message or the taking of any action based on its contents, other than by the intended recipient for its intended purpose, is strictly prohibited. If you have received this e-mail in error, please notify the sender immediately and delete it from your system. Email transmission cannot be guaranteed to be error-free or secure or free from viruses, and Eversource Energy disclaims all liability for any resulting damage, errors, or omissions. 17cv1906 Sierra Club v. EPA ED_001523_00000733-00001 forwarc(Z' THE NORTHERN PASS October 7, 2017 Northern Pass Transmission, LLC. P.O. Box 330 780 North Commercial Street Manchester, NH 03105-0330 Jennifer McCarthy, Chief Regulatory Division U.S. Army Corp of Engineers New England District 696 Virginia Road Concord, MA 01742 Re: Northern Pass Transmission Project -- Response to EPA Comment Letter Dear Ms. McCarthy: I write in response to the September 26, 2017 letter from Jaqueline LeClair from the U.S. Environmental Protection Agency, Region I, commenting on the Northern Pass Transmission Project (NPT) Section 404 Permit Application. In her letter, Ms. LeClair briefly compares wetlands impacts from the proposed route to the so-called "hybrid" alternative of placing the Northern Pass line underground along highway rights of way in the north section of the route. EPA asserts that this alternative "appears practicable." As explained in the letter to you of October 6, 2016 -- responding to a very similar comment letter from EPA dated July 14, 2016 -- the proposed alternative is the least environmentally damaging practicable alternative. This is fully addressed in the letter of October 6, 2016, and the accompanying confidential document entitled An evaluation ofall UG alternatives for the Northern Pass Transmission Project, dated May 31, 2016. (That confidential report was submitted separately to you on October 6, 2016 by Dana Bisbee, legal counsel for NPT.) NPT has exhaustively worked to design the Project to avoid wetlands impacts. The resulting design will have extremely small permanent impacts to wetlands, and the unavoidable temporary and secondary impacts will be fully restored and/or mitigated. As we have fully addressed in our prior correspondence, constructing an additional 32 miles in the north section of the Project is not practicable. EPA's calculation in its September 26, 2017 letter that the estimated increased costs "represent a small portion of the overall Project costs" does not take into account the substantial additional costs of undergrounding the Project. As set forth in the October 6, 2016 letter, these increased expenses would mean that the Project would not be viable in the New England power market. I would also note that subsequent to EPA's initial set of comments and NPT's reply to those comments, the New Hampshire Department of Environmental Services has considered these same issues in the context of its state wetlands permitting decision. In its March 1, 2017 recommended decision, DES determined that Northern Pass had satisfied the comparable state 17cv1906 Sierra Club v. EPA ED_001523_00000734-00001 requirement (NH Code of Admin. Rules Env-Wt 302.03) that the applicants demonstrate that the project avoids wetlands impacts to the maximum extent practicable. For your ease of reference, I have attached a copy of the letter to you dated October 6, 2016. Please let us know if you have any questions. Sincerely, Kevin McCune Cc: w/o enclosures: Jacqueline LeClair, USEPA Deborah Szaro, USEPA Lindsey Lefebvre , USAGE Mark Kem, USEPA Brian Mills, USDOE Robert Scott, Commissioner, NHDES Rene Pelletier, NHDES Collis Adams, NHDES Craig Rennie, NHDES Enclosures 17cv1906 Sierra Club v. EPA ED_001523_00000734-00002