Pastoriza: Eversource Transmission Line Rebuild Plan Is Deficient, Lacks Details

By Kris Pastoriza, InDepth NH

The public utility Eversource plans a massive rebuild of its X-178 115 kV transmission line through 12 miles of White Mountain Forest, from Route 116 in Easton across the Reel Brook Trail, Appalachian Trail, and Bog Pond, to Woodstock.

The National Environmental Policy Act (NEPA) requires federal agencies such as the Forest Service responsible for the White Mountain National Forest (WMNF) to assess the environmental impacts of their proposed actions prior to making decisions regarding the use of the forest. For example, WMNF logging projects routinely receive a NEPA Environmental Assessment consisting of a substantial project summary and 10-20 other documents including logging plans, maps, socioeconomic studies, project rationales, production of CO2, and studies of project effects on plants, animals and watersheds.

The Forest Service decided that Eversource’s X-178 rebuild project, which would replace 140 wood structures with taller and wider metal structures and construct a permanent heavy equipment road on the easement and permanent level 100’ x 100’ construction pads around each structure, should be granted Categorical Exclusion (CE) from the environmental review required by NEPA.

The only information the Forest Service has publicly posted on its proposed CE is a 4 ½ page description of the project. This document contains very few details and no maps or project plans.

The Forest Service has not posted the 170-page application Eversource submitted supporting its application for a CE. It took a Freedom of Information Act (FOIA) to find that critical document which includes the project plans, a photo log of the line, correspondence with Fish and Game, US Fish and Wildlife and the Natural Heritage Bureau and an inventory of trees Eversource would cut to build its access roads.

The application is deficient and lacks essential details to qualify the exclusion of the project from NEPA review.

The missing project plans for example, show the Appalachian Trail (dashed yellow line) covered by a 100’ x 100’ permanent, leveled and compacted gravel construction pad. Hikers on the AT would have a clear view of Eversource’s planned 50’ x 100’ leveled and graveled conductor pull pad and construction pad at the next structure, as shown below.

Eversource represents that it will drill micropile foundations, using helicopter access only for the structures shown above at the Appalachian Trail and 21 other structures in WMNF, to eliminate the road (dashed light-yellow line) and reduce the size of the construction pads and amount of backfill required to level the pads. For the rest of the structures the cut and fill would be massive on steep terrain, requiring trucks and heavy equipment on roads to the site. If helicopter service is not feasible, the Forest Service plans to allow Eversource to retain the right to construct access roads and its standard 100’ x 100’ pads.

Micropile foundations are not micro above the ground, as is shown in a document sent by Eversource to the Forest Service but not included in the 4 ½ page CE application.

As a visual example, below is a 360 panorama view taken from the middle of a pull-pad on Eversource’s U-199 transmission line replacement project. The project plans for this section are the same as for the Appalachian Trail crossing except that the pull-pad is 25’ longer, extending completely between the two construction pads:

The construction on the U-199 is Eversource’s boiler-plate rebuild method and an accurate example of what Eversource would be permitted to construct at the Appalachian Trail crossing of the transmission easement, and other locations in WMNF, if the Forest Service gives Eversource a CE.

The WMNF Forest Plan prohibits new utility lines or rights-of-way from crossing the AT “unless they represent the only feasible and prudent alternative to meet an overriding public need.”

The Forest Service is accepting comments on Eversource’s application to the Forest Service for this Categorical Exception.

Comments submitted to WMNF could address:

• The lack of any determination by ISO-NE or any responsible body, of public need for a rebuild of the X-178.

• The need for the Forest Service to require Eversource to produce an Environmental Impact Statement for the project after a thorough NEPA review.

• The need for an explanation of how the permanent roads and construction pads would provide emergency access when the removal of wetlands matting after construction would divide them into more than 80 segments separated by wetlands,

• The missing explanation of how the Forest Service can allow road-building in two Roadless Areas. (On June 23^rd 2025 U.S. Secretary of Agriculture Brooke L. Rollins rescinded the 2001 Roadless Rule but this act will be challenged.)

• The need for the Forest Service to post:

1.) The project plans, construction specifications including grading and fill plans, road construction plans, drainage plans, feasibility of tower installation by helicopter and the 170 page CE application submitted by Eversource that led to the 4 ½ page summary approval of the project as appropriate to exclude the project from NEPA review

2.) Geotechnical boring plans for the micropile foundations including plans (there are none) for dealing with frak-out (leaking) of drilling fluids to Bog Pond,

3.) Approval from U.S. Fish and Wildlife for effects on endangered species,

4.) The list of structure height increases,

5.) Alteration of Terrain, and Dredge and Fill wetlands applications and permits from DES,

6.) Profile drawings showing the structures and the height and clearance to ground of the existing conductors, the proposed new conductors, advanced conductors, and the specifications of the proposed Optical Ground Wire (OPGW) together with the plans and specifications for grounding the OPGW under the construction pads.

7.) Visual impact maps,

8.) Proper ISO-NE planning review as required by the Federal Energy Regulatory Commission (FERC) Orders 1920 and 1920-A, including third-party structure inspection reports to confirm or deny Eversource’s claim that the X-178 needs replacement.

Comments can be sent to Forest Supervisor Derek Ibarguen: Derek.Ibarguen@usda.gov

Pemi. District Ranger Brooke Brown: brooke.brown@usda.gov

Project contact Marianne Leberman marianne.leberman@usda.gov

Kris Pastoriza lives in Easton. She believes the project will impact the beauty of her property and will permanently scar the White Mountain National Forest with roads and tower pads.

This article first appeared on InDepthNH.org and is republished here under a Creative Commons license.