Unless you live completely off the grid, you cannot have missed the impressive advertising campaign for the Northern Pass Project, which proposes building 140 miles of electric transmission lines through New Hampshire to bring Canadian electricity to New England. These daily print and television ads, which feature "real" New Hampshire people who support the Northern Pass Project, are everywhere, it seems.

A little less in your face are the voices of the many opposed. Citizens, local governments, the environmental community, and the tourism industry have voiced their objections to the Northern Pass Project in letters to the editor and town meeting warrant articles, on websites and lawn signs, in songs and demonstrations, and with orange balloons that match the height of the 135' high towers that might one day criss-cross the White Mountains.

In a much less colorful way, but with facts we hope will inform the debate, the New England Power Generators Association (NEPGA) has just issued a paper voicing our members' position on the Northern Pass Project. Simply put, NEPGA maintains that no power project deserves special treatment by regulators. We strongly believe that the Northern Pass Project needs to follow the same rules as its competitors and operate on a level playing field. Trying to game the system and gain unfair advantages in the marketplace is just wrong. This line is unnecessary and costly. When additional power is needed to meet the demand of consumers, put competition to work and ensure that a fair market can deliver those results.

To be clear, NEPGA is made up of competitive electric generating companies in New England. Our member companies represent approximately 27,000 megawatts (MW) -- or nearly 85 percent -- of generating capacity throughout New England. These same companies provide nearly 5,500 well-paying and skilled manufacturing jobs, while contributing millions of dollars to charitable endeavors throughout the region. Overall, NEPGA's companies pay over $190 million annually in state and local taxes.

NEPGA's arguments against the Northern Pass Project can be broken down into these four areas:

â?¢ The Northern Pass Project's request to use eminent domain to take private property along the proposed route is wrong. This project is a private facility and, simply put, neither New England nor New Hampshire needs the power. Using eminent domain violates both the state Constitution and the regulatory process. Other competitive electricity projects, like generation and transmission projects, do not use eminent domain, so this would give the Northern Pass Project an unfair advantage in the marketplace.

â?¢ The renewable energy portfolio standard (RPS) should not be expanded for large Canadian hydro. Representatives of the Northern Pass Project have said they want to change state laws to allow power from their project to qualify as renewable under market-based RPS programs and gain an added subsidy from consumers. Qualifying large-scale hydro projects will overwhelm the RPS programs in New England, undermine the value of existing and future renewable projects, and slow the development of local renewable power projects.

â?¢ A no-bid, sole-source contract is bad for consumers. PSNH wants to change state law to direct the Public Utilities Commission (PUC) to approve a 40-year power purchase agreement. This will allow them to enter into a no-bid, sole-source contract with the Northern Pass Project to purchase power and supply their default service customers. This type of supply, if it is needed, should be procured through a competitive bid process. This gives all market participants the opportunity to compete, and guarantees the lowest cost for consumers. NEPGA further questions the appropriateness of PSNH contracting with a project in which they and their affiliates have a commercial interest.

â?¢ Unregulated subsidies from regulated utilities are bad for consumers. As a franchised regulated distribution company, PSNH has a duty, and is legally required, to maintain a fair and open system that treats all customers and suppliers equally. In conflict with that clear duty, PSNH is providing the Northern Pass project special treatment. At a minimum, it is questionable for a distribution utility to promote the development of any generation project; if however, a utility opts to promote any project, they must do so equally for all generators. PSNH should refrain from promoting the Northern Pass Project and instead focus more properly on its obligation to treat consumers and suppliers equally.

NEPGA expects policymakers to closely scrutinize the Northern Pass Project in the months to come and we look forward to working in this process to ensure that a level playing field is maintained. Our Association's mission is to promote sound energy policies which will further economic development, jobs, and balanced environmental policy. Special treatment for any entity conflicts with those goals. In the end, the people of New Hampshire are best served when a competitive process between companies determine the best resources to meet consumers' needs.

Sandi Hennequin is a vice president at the New England Power Generators Association (NEPGA) and lives in Portsmouth, N.H. NEPGA is a private, non-profit entity that advocates for the business interests of non-utility electric power generators in New England. NEPGA has offices located in Boston. NEPGA's New Hampshire members have 13 facilities in the state.


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