The New England States Committee on Electricity (NESCOE) is raising the alarm on Eversource Energy’s planned rebuild of the X-178 transmission line in New Hampshire, arguing the company has not adequately justified the need for the full $385 million project. 

Eversource initially presented the replacement project for the 115-kV line to the ISO-NE Planning Advisory Committee in February. It provided a follow-up presentation to the PAC in June, concluding that a full line rebuild would be more cost-effective than a partial rebuild in the long term. (See ISO-NE PAC Briefs: June 20, 2024.) 

“Based on the information that Eversource has shared to date, NESCOE is not persuaded that this investment is a reasonable use of consumer dollars,” NESCOE wrote in a memo published Aug. 1, adding the company has not sufficiently responded to NESCOE’s requests for information on the project.  

“Absent information showing that this use of consumer dollars is well-supported and reasonable, NESCOE is prepared to use its full resources to explore all available options to dispute the reasonableness of the investments, including but not limited to action at FERC,” the committee added.  

Escalating costs from asset condition projects, which are intended to upgrade aging and degrading transmission infrastructure, have been a major concern of the New England states over the past year. NESCOE has pushed New England transmission owners for reforms to the asset condition review process at the PAC to provide greater transparency and allow for more stakeholder engagement. 

NESCOE noted in a June memo that the transmission owners have introduced more than $3 billion in asset condition projects to the PAC since the committee first called for reforms in February 2023.  

The $385 million project at issue in the memo is not the largest asset condition project proposed this year; in May, National Grid presented a nearly $500 million project. (See ISO-NE Planning Advisory Committee Briefs: May 15, 2024.)  

Eversource’s X-178 project has drawn additional scrutiny in part because Eversource’s evaluation of the line identified just 43 of the line’s 594 structures as high-priority concerns, and many of the structures are younger than their projected lifespans. 

In response to NESCOE’s prior calls for asset condition process reforms, the transmission owners have made changes to allow for more stakeholder feedback and have added a new asset condition project forecast database and a process guide.  

NESCOE has called the process updates inadequate and wrote Aug. 1 that Eversource’s decision to push forward with the X-178 project despite the objections raised by stakeholders shows more work needs to be done. 

“Eversource’s persistence in claiming this project is cost-effective without providing the necessary cost details to allow stakeholders to ascertain the reasonableness of this statement underscores the continued need for a comprehensive Asset Condition Needs and Solution Guidance document,” NESCOE wrote.  

The PAC review process for asset condition projects exists strictly for informational purposes and has no regulatory authority. The prudency review of asset condition projects is under federal jurisdiction, while states have jurisdiction over local land and environmental impacts. 

Eversource spokesperson William Hinkle said in a statement the company is reviewing NESCOE’s memo, adding that the company is complying with all regulatory requirements for the project and has undertaken “extensive community outreach efforts” beyond what is required for the project. 

“Line rebuilds such as this, and asset condition projects more generally, are critical to enhancing reliability for customers as we make the transmission system more resilient to the increasingly extreme weather we’re experiencing in New England and addressing aging infrastructure that in many cases was originally built over 50 years ago,” Hinkle said. 

At an investor call Aug. 1, Eversource CEO Joe Nolan said replacing aging transmission infrastructure is a key component of the company’s business strategy amid its retreat from the offshore wind business. 

Nolan said the company is focused on “resiliency investments to address aging infrastructure and minimize customer outages,” in conjunction with investments to enable load growth and clean energy resources.  

He added that the company’s five-year plan includes $3 billion in investments to replace aging transmission infrastructure, $1 billion for building and upgrading substations, and $600 million for transmission upgrades to enable new renewable generation. 

New Hampshire Consumer Advocate Don Kreis said NESCOE’s strongly worded complaint is significant given the committee’s typically diplomatic approach, as comments from NESCOE represent the collective views of all six New England governors.  

Kreis said it’s important that the memo “really isn’t just talking about the X-178 line,” but instead is aimed at the broader lack of oversight on asset condition projects. 

While states cannot review the prudence of the investment, Kreis expressed his hope that the New Hampshire Site Evaluation Committee will take up a review of the project. He said a potential state review process “could be a test of [FERC Commissioner Mark Christie’s] hypothesis that the states can and should play a key role in determining whether projects like this go forward.”