June 29, 2020 Via Electronic Filing Michelle L

ATTORNEYS AT LAW

EXECUTIVE WOODS, FIVE PALISADES DRIVE, ALBANY, NY 12205 Phone: 518-438-9907 • Fax: 518-438-9914

www.youngsommer.com Writer’s Telephone: 272 [email protected]

June 29, 2020 Via Electronic Filing Michelle L. Phillips Secretary to the Commission NYS Department of Public Service Three Empire State Plaza Albany, NY12223-1350

Re: Case 17-F-0655: Application of Riverhead Solar 2, LLC for a Certificate of Environmental Compatibility and Public Need Pursuant to Article 10 for Construction of a Solar Electric Generating Facility Located in the Town of Riverhead, Suffolk County.

Dear Secretary Phillips:

We represent the Applicant, Riverhead Solar 2, LLC, in the above-referenced proceeding. Riverhead Solar 2, LLC ("Riverhead Solar" or “Applicant”) is proposing to construct and operate a solar electric generating facility in the Town of Riverhead, Suffolk County, New York (the "Facility"). To construct and operate the Facility, Riverhead Solar is seeking a certificate of environmental compatibility and public need from the New York State Board on Electric Generation Siting and the Environment (the "Siting Board") pursuant to Article 10 of the Public Service Law (PSL) and the Siting Board's rules (16 NYCRR Part 1000 et seq.).

Pursuant to PSL § 164 and 16 NYCRR § 1000.6, and as agreed by the parties in executed stipulations, Riverhead Solar hereby files its Application electronically with the Secretary through the Public Service Commission's Document Matter Management (DMM) System. A check for application intervenor funding as required by PSL § 164(6) has been filed under separate cover.

The Application follows the statutory requirements of Article 10 (PSL § 164(1)), the Siting Board's rules (16 NYCRR Part 1001 et seq.), and the executed Stipulations. The Application contains, among other things, a description of the proposed Facility and the studies or program of studies conducted to evaluate potentially significant adverse environmental and health impacts, and the results of those studies along with proposed avoidance, minimization and mitigation measures, where necessary.

Enclosed with the Application is the testimony of each expert witness the Applicant intends to offer at any hearing as required by PSL § 165 (16 NYCRR § 1000.6(c)(1)). The testimony includes the qualification of each witness and specifies the portion of the Application for which each witness is responsible for or supports. (See Attachment 1 to this letter for copies of the pre-filed testimony.)

Pursuant to PSL § 164(2) and 16 NYCRR § 1000.6(a), copies of the Application are being served upon the parties listed on the attached service list. (See Attachment 2 of this letter for a copy of the Service List; an Affidavit of Service of same will be submitted once service has been effected.)

Pursuant to 16 NYCRR § 1000.7(a) and 1000.7(b)(1), notice of the Application with a summary and map (the "Application Notice") was published in the Riverhead News Review and RiverheadLOCAL.com on June 25, 2020, at least three (3) days in advance of the date on which the Application was filed as required by the applicable regulation. Copies of the Affidavits of Publication with the notice and proofs will be filed with the Siting Board upon receipt.

Pursuant to 16 NYCRR § 1000.7(b)(2), on June 24, 2020, which is at least three (3) days in advance of the date on which the Application was filed, a letter enclosing a copy of the Application Notice was served on each member of the State Legislature in whose district any portion of the Facility is proposed to be located. (See Attachment 3 for a copy of the letter and Application Notice, together with proof of service.) A similar letter was sent to the Supervisor for the Town of Riverhead on June 24, 2020.

Pursuant to 16 NYCRR § 1000.7(b)(3), on June 25, 2020, which is at least three (3) days in advance of the date on which the Application was filed, a copy of the Application Notice was served on all persons who have filed a statement with the Secretary to the Siting Board that they desire to receive all such notices by serving a copy of the notice on the Secretary for posting on DMM.

In addition, a copy of the Notice was submitted to the Master List of Stakeholders (Appendix 2-A) and uploaded to the website for the Project at: https://riverheadsolar2.spower.com/

Pursuant to 16 NYCRR § 1000.6(c)(5), the following are the names, addresses, telephone numbers and e-mail addresses of the Applicant and its Attorney:

Applicant: Applicant's Attorney: Riverhead Solar 2, LLC James A. Muscato II Michael Farrell YOUNG/SOMMER LLC 195 Montague Street Executive Woods 14th Floor, Suite 1461 5 Palisades Drive Brooklyn, NY 11201 Albany, New York 12205 Tel. No. (855) 561-6212 Tel. (518) 438-9907 ext. 243 [email protected] Fax (518) 438-9914 [email protected]

Finally, enclosed is a copy of the cover letter for the Applicant’s motion and comprehensive brief pursuant to 16 NYCRR § 6-1.4 submitted to the Presiding Examiners whereby the Applicant requests protection from public disclosure of certain information and documents contained in its Application. (See Attachment 4 for a copy of the letter requesting confidentiality.)

Please do not hesitate to call me with any questions.

Respectfully submitted,

James A. Muscato II Jessica Ansert Klami Attorney for Riverhead Solar 2, LLC

Enclosures: Attachment 1: Pre-Filed Testimony and Resumes Attachment 2: Application Service Lists Attachment 3: Affidavit of Service of Application Notice upon members of State Legislature Attachment 4: Request for Confidentiality and Brief

cc: Service List (via electronic and/or first-class mail pursuant to Attachment 2) Party List (via DMM)

Attachment 1

STATE OF NEW YORK PUBLIC SERVICE COMMISSION ______

Application of Riverhead Solar 2 for a Certificate Case No. 17-F-0655 of Environmental Compatibility and Public Need Pursuant to Article 10 of the New York Public Service Law for Construction of a Solar Electric Generating Facility Located in the Town of Riverhead, Suffolk County, New York ______

PRE-FILED TESTIMONY OF BENJAMIN R. BRAZELL PRINCIPAL ENVIRONMENTAL DESIGN & RESEARCH, LANDSCAPE, ARCHITECTURE, ENGINEERING & ENVIRONMENTAL SERVICES, D.P.C.

Case No. 17-F-0655 BRAZELL

1 Q: Please state your name, employer, and business address.

2 A: Benjamin R. Brazell, Environmental Design & Research, Landscape, Architecture, Engineering &

3 Environmental Services, D.P.C. (“EDR”), 217 Montgomery Street, Suite 1000, Syracuse, NY

4 13202-1942.

5 Q: What is your position at EDR?

6 A: Principal of Environmental Services.

7 Q: How long have you been employed with EDR?

8 A: I have been employed by EDR since 2004.

9 Q: Please describe your educational background and professional experience.

10 A: I received a Bachelor of Science Degree in Natural Resources Ecosystem Assessment from North

11 Carolina University in Raleigh, North Carolina in 2001. I have been employed by EDR since February

12 2004. Since that time, I have worked in the capacity as Project Manager, Manager of the

13 Environmental Division, and Associate before becoming Principal of Environmental Services in 2011.

14 I have nearly 20 years of experience performing and/or supervising projects involving wetlands

15 delineations, state and federal wetland permitting, habitat and ecosystem analysis, environmental

16 resource identification and impact assessments, and preparation of numerous state siting board

17 applications and environmental impact statements. A copy of my resume is submitted as Exhibit

18 ____ (BB-PF1): Resume of Benjamin Brazell.

19 Q: Please describe your current responsibilities with EDR.

20 A: As Principal, I oversee all aspects of EDR’s environmental assessment projects.

21 Q: Have you previously testified before the New York State Public Service Commission or

22 Siting Board on Electric Generation?

23 A: I provided written rebuttal and sur-rebuttal testimony, and was subject to cross examination under

24 oath, pursuant to Article 10 in the Matter of Cassadaga Wind LLC and in the Matter of Baron Winds Case No. 17-F-0655 BRAZELL

25 LLC (Case No. 15-F-0122) In addition, I prepared written rebuttal testimony in the Matter of Canisteo

26 Wind Energy LLC (Case No. 16-F-0205) and in the Matter of Alle-Catt Wind Energy LLC (Case No.

27 17-F-0282). I have previously sponsored testimony in the Matter of National Grid’s petition to Amend

28 the Article VII Certificate of Environmental Compatibility and Public Need for the 115 kV Fenner to

29 Cortland #3 (formerly the Oneida to Cortland #3, PSC Case 70346) Transmission Line.

30 Q: Have you previously served as an expert witness before any other court, agency, or other

31 body on the subject you plan to offer testimony on today?

32 A: I previously served as an expert witness for numerous renewable energy cases before the Ohio

33 Power Siting Board, including the Matter of Paulding Wind Farm III LLC (Case No. 15-1737-EL-

34 BTX), the Matter of Icebreaker Windpower Inc. (Case No. 16-1871-EL-BGN), and the Matter of

35 Hillcrest Solar I, LLC (Case No. 17-1152-EL-BN).

36 Q: What is the purpose and scope of your testimony in this proceeding?

37 A: To sponsor certain portions of the Riverhead Solar 2 Application or the Exhibits thereto.

38 Q: What portion(s) of the Application is your testimony sponsoring or co-sponsoring?

39 A: Exhibit 2: General Requirements, Exhibit 3: Location of Facilities, Exhibit 9: Alternatives, Exhibit 10:

40 Consistency with Energy Planning Objectives, Exhibit 17: Air Emissions, Exhibit 22: Terrestrial

41 Ecology and Wetlands, Exhibit 23: Water Resources and Aquatic Ecology, Exhibit 28:

42 Environmental Justice, Exhibit 31: Local Laws and Ordinances, Exhibit 32: State Laws and

43 Regulations, Exhibit 33: Other Applications and Filings

44 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

45 direction and supervision.

46 A: Yes. Case No. 17-F-0655 BRAZELL

47 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

48 or documents produced by persons other than yourself/your company? If so, please cite

49 these sources. [These are independent studies, etc.]

50 A: References are provided in the corresponding Application Exhibits.

51 Q: Does this conclude your testimony?

52 A: Yes.

Benjamin R. Brazell, Principal Environmental Services

Ben is currently a Principal and the Manager of Environmental Services for Environmental Design & Research, Landscape Architecture & Engineering, D.P.C. With nearly 20 years of environmental consulting experience, Mr. Brazell has been directly involved in the environmental review and permitting of over 50 commercial wind power projects and approximately 20 commercial solar power projects (primarily located in New York and Ohio). Mr. Brazell’s specialized expertise includes environmental impact analysis, natural resources surveys and evaluation, state and federal wetland permitting, and managing large-scale, complex projects. He is currently serving as the Principal-in-Charge of multiple solar and wind power projects seeking a Certificate of Environmental Compatibility and Public Need under various state siting board regulatory processes. He has significant expertise with Article 10 of the New York State Public Service Law, the New York State Environmental Quality Review Act (SEQRA), and Ohio Power Siting Board (OPSB) certification and permitting. As the Manager of Environmental Services with EDR, Ben oversees the firm’s environmental and natural resources evaluation and permitting services. He has extensive experience providing environmental consulting services for utility-scale renewable energy projects.

education employment history Bachelor of Science, Natural Resources: Ecosystem Assessment, North Principal of Environmental Services, Environmental Design & Research, Carolina State University, 2001 Landscape Architecture, Engineering & Environmental Services, D.P.C., Syracuse, NY, 2011 - Present.

Associate, Environmental Design & Research, Landscape Architecture, professional affiliations Engineering & Environmental Services, D.P.C., Syracuse, NY, 2010 - 2011. Member, New York State Wetlands Forum Environmental Division Manager, Environmental Design & Research, Member, American Wind Energy Association Landscape Architecture, Engineering & Environmental Services, D.P.C., Member, American Wind Energy Association Siting & Environmental Syracuse, NY, 2009 - Present. Compliance Committee Project Manager, Environmental Design & Research, Landscape Architecture, Engineering & Environmental Services, D.P.C., Syracuse, NY, 2004 - 2008.

Project Scientist, EcoScience Corporation, Raleigh, NC, 2001 - 2003.

Dendrology Tutor, North Carolina State University, 2001.

select project experience Cassadaga Wind Project – Served as Project Manager and Principal-in-Charge of environmental analysis and permitting services for this 126 MW wind power project located in the Towns of Cherry Creek, Charlotte, Arkwright, and Stockton, Chautauqua County, NY. This project represents the first Application prepared and submitted under Article 10 of the New York State Public Service Law, and the first project to receive an Article 10 Certificate. EDR was responsible for preparation of the Public Involvement Program Plan, the Preliminary Scoping Statement, Stipulations document, multiple support studies and analyses, the Article 10 Application, Article 10 Application Supplements, and expert witness testimony. The Order granting a Certificate of Environmental Compatibility and Public Need was issued by the Siting Board on January 17, 2018. Baron Winds Project – Served as Project Manager and Principal-in-Charge of environmental analysis and permitting services for this 242 MW project located in the Towns of Avoca, Cohocton, Dansville, Fremont, Howard, and Wayland, Steuben County, New York. EDR was responsible for preparation of the Public Involvement Program Plan, the Preliminary Scoping Statement, Stipulations document, multiple support studies and analyses, the Article 10 Application, Article 10 Application Supplements, and expert witness testimony. The Order granting a Certificate of Environmental Compatibility and Public Need was issued by the Siting Board on September 12, 2019.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

BB-PF1 Page 1 of 3

Benjamin R. Brazell, Principal Environmental Services

Bluestone Wind Project – Served as Principal-in-Charge of environmental analysis and permitting services for this 125 MW project located in the Towns of Sandford and Windsor, Broome County, New York. EDR was responsible for preparation of the Public Involvement Program Plan, the Preliminary Scoping Statement, Stipulations document, multiple support studies and analyses, the Article 10 Application, Article 10 Application Supplements, and expert witness testimony. The Order granting a Certificate of Environmental Compatibility and Public Need was issued by the Siting Board on December 16, 2019. Canisteo Wind Project - Served as Principal-in-Charge of environmental analysis and permitting services for this 290 MW project located in the Towns of Cameron, Greenwood, Jasper, Troupsburg, and West Union, Steuben County, New York. EDR was responsible for assistance with various aspects of the pre-application phase such as public outreach, response to Preliminary Scoping Statement comments, and Stipulations, the preparation of multiple support studies, analyses, and portions of the Article 10 Application, Article 10 Application Supplements, and expert witness testimony. The Order granting a Certificate of Environmental Compatibility and Public Need was issued by the Siting Board on March 13, 2020. Alle-Catt Wind Project - Served as Principal-in-Charge of environmental analysis and permitting services for this 340 MW project located in the Towns of Arcade, Centerville, Farmersville, Freedom, and Rushford, Allegany, Cattaraugus, and Wyoming Counties, New York. EDR was responsible for assistance with various aspects of the pre-application phase such as public outreach, response to Preliminary Scoping Statement comments, and Stipulations, the preparation of multiple support studies, analyses, and portions of the Article 10 Application, Article 10 Application Supplements, and expert witness testimony. The Order granting a Certificate of Environmental Compatibility and Public Need was issued by the Siting Board on June 3, 2020. Mohawk Solar Project – Served as senior technical advisor on environmental analysis and permitting for this 90 MW project located in the Towns of Canajoharie and Minden, Montgomery County, New York. EDR was responsible for preparation of the Public Involvement Program Plan, the Preliminary Scoping Statement, Stipulations document, multiple support studies and analyses, the Article 10 Application, Article 10 Application Supplements, and expert witness testimony. This project represents the first Application prepared and submitted for a solar project under Article 10 of the New York State Public Service Law. Willowbrook Solar Project - Served as Project Manager and Principal-in-Charge of environmental analysis and permitting services for this 150 MW project located in Highland and Brown Counties, Ohio. EDR's responsibilities included coordinating with Ohio Power Siting Board staff, external consulting and engineering firms, and the applicant to prepare a Siting Board Application in accordance with the requirements of the Ohio Administrative Code. The Opinion, Order, and Certificate was granted by the Ohio Power Siting Board on April 4, 2019. Hillcrest Solar Project - Served as Project Manager and Principal-in-Charge of environmental analysis and permitting services for this 125 MW project located in Brown County, Ohio. EDR's responsibilities included coordinating with Ohio Power Siting Board staff, external consulting and engineering firms, and the applicant to prepare a Siting Board Application in accordance with the requirements of the Ohio Administrative Code. This project represents the first solar power Application submitted to the Ohio Power Siting Board, and the first solar project to receive a Certificate. The Opinion, Order, and Certificate was granted by the Ohio Power Siting Board on February 15, 2018. Icebreaker Wind Project - Served as Project Manager and Principal-in-Charge of environmental analysis and permitting services for this 21 MW project located in Lake Erie, Ohio. EDR's responsibilities included coordinating with Ohio Power Siting Board staff, external consulting and engineering firms, and the applicant to prepare a Siting Board Application in accordance with the requirements of the Ohio Administrative Code. This project represents the first freshwater offshore wind project in Ohio and also the first freshwater offshore wind project in North America. The Opinion, Order, and Certificate was granted by the Ohio Power Siting Board on May 21, 2020. Timber Road IV Wind Farm – Served as Project Manager and Principal-in-Charge of environmental analysis and permitting for this 125 MW project located in Paulding County, Ohio. EDR's responsibilities included coordinating with Ohio Power Siting Board staff, external consulting and engineering firms, and the applicant to prepare a Siting Board Application in accordance with the requirements of the Ohio Administrative Code. The Opinion, Order, and Certificate was granted by the Ohio Power Siting Board on February 21, 2019. Jericho Rise Wind Farm – Served as Principal-in-Charge of environmental analysis and permitting services for this 37-turbine, 78 MW project, located in the Towns of Bellmont and Chateauguay, Franklin County, New York. EDR prepared a Supplemental EIS, a Final EIS, and multiple support studies including a Visual Impact Assessment, Shadow Flicker Analysis, Cultural Resources Reports (Archaeology and Historic Resources), a Wetland Delineation Report, and a Rare Plant Survey. EDR also obtained wetland/stream permits from the U.S. Army Corps of Engineers and the NYS Department of Environmental Conservation. Arkwright Summit Wind Farm – Served as Principal-in-Charge of environmental analysis and permitting services for this 36-turbine, 78 MW project, located in the Town of Arkwright, Chautauqua County, New York. EDR prepared a Supplemental EIS, a Final EIS, and multiple support studies including Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

BB-PF1 Page 2 of 3

Benjamin R. Brazell, Principal Environmental Services a Visual Impact Assessment and Shadow Flicker Analysis. EDR is also responsible for obtaining wetland/stream permits from the U.S. Army Corps of Engineers and the NYS Department of Environmental Conservation. Scioto Ridge Wind Farm - Managed the preparation of a Certificate Application submitted to the Ohio Power Siting Board for this 176-turbine, 300 MW project located in Hardin and Logan Counties, Ohio. EDR's responsibilities included attending work sessions with OPSB staff, directing other subconsultants, coordinating internal staff resources, and assuring a complete application was prepared/submitted in accordance with the Ohio Administrative Code. Also managed the preparation of a separate Certificate Application for the associated 4.8-mile 345 kilovolt transmission line. The Opinion, Order, and Certificate was granted by the Ohio Power Siting Board on March 17, 2014. Copenhagen Wind Project - Directed EDR’s responsibilities as a third-party consultant to the USFWS. As a result of potential impacts to federally- listed species, the developer is applying for an Incidental Take Permit. EDR is responsible for preparing all NEPA documentation associated with this action. Buckeye II Wind Power Project - Managed the preparation of a comprehensive Application for a Certificate of Environmental Compatibility and Public Need submitted to the Ohio Power Siting Board for this 56-turbine, 140 MW project located in Champaign County, Ohio. EDR's responsibilities included conducting initial site reconnaissance to define the project layout, attending various work sessions with OPSB review staff, directing other subconsultants, coordinating internal staff resources, and assuring a complete application was prepared/submitted in accordance with the Ohio Administrative Code. Allegany Wind Power Project - Directed EDR’s SEQRA review for this 29-turbine, 72.5 MW project, located in the Town of Allegany, Cattaraugus County, New York. EDR prepared a Draft and a Final EIS, which resulted in successful issuance of SEQRA findings statement and local discretionary approvals in July 2011. Through these efforts, EDR has worked closely with the Lead Agency Special Counsel and consultant throughout the SEQRA review process, coordinated with interested state and federal regulatory agencies, and managed numerous subconsultants. EDR was also responsible for preparation of the SWPPP in accordance with the SPDES General Permit, which was approved by the NYSDEC in September 2011. Timber Road II Wind Farm - Managed the preparation of a comprehensive Application for a Certificate of Environmental Compatibility and Public Need submitted to the Ohio Power Siting Board for this 109-turbine, 150 MW project located in Paulding County, Ohio. EDR's responsibilities included attending various work sessions with OPSB review staff, directing other subconsultants, coordinating internal staff resources, and assuring a complete application was prepared/submitted in accordance with the Ohio Administrative Code. Irrespective of the project’s aggressive schedule, EDR played a critical role in meeting the permitting deadline. Timber Road I Wind Farm - Managed the preparation of a comprehensive Application for a Certificate of Environmental Compatibility and Public Need submitted to the Ohio Power Siting Board for this 35-turbine, 49 MW project located in Paulding County, Ohio. EDR's responsibilities included attending various work sessions with OPSB review staff, directing other subconsultants, coordinating internal staff resources, and assuring a complete application was prepared/submitted in accordance with the Ohio Administrative Code. Buckeye Wind Power Project - Managed the preparation of the first ever Application for a Certificate of Environmental Compatibility and Public Need submitted to the Ohio Power Siting Board for a wind power project in Ohio. This 70-turbine, approximately 130 MW project is located in Champaign County, Ohio. EDR's experience in the wind industry proved invaluable when working OPSB staff, interpreting the State of Ohio’s new wind law, directing the efforts of local consulting firms, and coordinating with the project sponsor and legal counsel. The Application was accepted as complete after the first submission. Howard Wind Power Project - Led EDR’s SEQRA review for this 25-turbine, 62 MW project, located in the Town of Howard, Steuben County, New York. EDR prepared a Draft and Final EIS, and worked closely with the Lead Agency Special Counsel and consultant throughout the SEQRA review process. EDR also assisted the Lead Agency in their issuance of a Findings Statement, and obtained a local Special Use Permit. In addition, EDR obtained NYSDEC authorization under Section 401 of the Clean Water Act, and U.S. Army Corps of Engineers authorization under Section 404 of the Clean Water Act.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 3 www.edrdpc.com

BB-PF1 Page 3 of 3 NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

BRUCE W. FAIRLESS, P.E.

GZA GEOENVIRONMENTAL OF NY

Case No. 17-F-0655 FAIRLESS

1 Q: Please state your name, employer, and business address.

2 A: Bruce W. Fairless, GZA GeoEnvironmental of NY, 104 W 29th St, 10th floor, NYC NY 10001.

3 Q: What is your position at GZA?

4 A: Principal.

5 Q: How long have you been employed with GZA?

6 A: 32 years..

7 Q: Please describe your educational background and professional experience.

8 A: Bachelor in Civil Engineering, Canterbury University, Christchurch, New Zealand; Master of

9 Geotechnical Engineering, University of Colorado, Boulder, Colorado, USA. Professional Engineer

10 in MA, CT, RI and NY A copy of my resume is submitted as Exhibit ____ (BWF-PF1: Resume of

11 Bruce Fairless.

12 Q: Please describe your current responsibilities with GZA.

13 A: Boston Office Manager, Senior Geotechnical Engineer, One of GZA’s Solar Services leaders since

14 2013.

15 Q: Have you previously testified before the New York State Public Service Commission or

16 Siting Board on Electric Generation?

17 A: No.

18 Q: Have you previously served as an expert witness before any other court, agency, or other

19 body on the subject you plan to offer testimony on today?

20 A: No.

21 Q: What is the purpose and scope of your testimony in this proceeding?

22 A: To sponsor certain portions of the Solar Riverhead Solar 2 Project Application or the Exhibits

23 thereto.

24 Q: What portion(s) of the Application is your testimony sponsoring?

Page 2 of 3

Case No. 17-F-0655 FAIRLESS

1 A: Exhibit 21: Geo-technical Report.

2 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

3 direction and supervision.

4 A: Yes.

5 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

6 or documents produced by persons other than yourself/your company? If so, please cite

7 these sources.

8 A: No.

9 Q: Does this conclude your testimony?

10 A: Yes.

Page 3 of 3

Bruce W. Fairless, P.E., LEED AP Principal

Summary of Experience Mr. Fairless has 32 years of experience in geotechnical engineering including design and construction of shallow and deep foundations (including caissons, piles and slurry walls); sheet pile, slurry wall and soldier pile/lagging earth support systems, and

bedrock blasting and major earthwork projects. Other experience includes solar

projects, subsurface geotechnical investigations and geotechnical instrumentation. He Education leads GZA’s geothermal and MA solar services team. He also has considerable B.E., 1983, Civil Engineering, experience with characterization of soil for off-site disposal. University of Canterbury Christchurch, New Zealand Bruce’s Solar Client List: M.S., 1985, Geotechnical Engineering Borrego, SunRaise, Beaumont, Omni Navitas, PV Engineers, Engie, Renewable University of Colorado at Boulder Properties, Solar Design Associates, NSG, True Green Capital, ECA Solar,

Registrations & Certificates SPower Professional Engineer – Massachusetts, Solar Project Experience #35833 Professional Engineer – Connecticut Principal in Charge, 100+ sites over 7 years in Massachusetts, Connecticut, New #28542 Hampshire, and New York, Geotechnical Studies for Borrego Solar. GZA Professional Engineer Rhode Island, – performed explorations and foundation studies for ground mounted solar arrays. #11386 Typical preferred systems were short driven piles or proprietary ground screw system. Professional Engineer – New York, #094703-1 Based on GZA test boring, test pits and laboratory data GZA prepared a geotechnical 2009, LEEDTM Accredited Professional report for each site. GZA prepared a pile design based on load combinations provided U.S. Green Building Council by Borrego on some sites. GZA also performed Northern long-Eared Bat habitat studies on 20 New England sites. Affiliations Principal in Charge, Geotechnical Studies for BlueWave Solar; 20+ sites, MA. GZA • American Society of Civil Engineers performed test pit explorations and prepared geotechnical reports for ground-mount • Boston Society of Civil Engineers • New England Geothermal solar projects. GZA typically recommends short driven piles or proprietary ground Professionals Association screw system, provided the design-build contractor. • Urban Land Institute Geotechnical Studies for Carport Solar at 40+ sites in New England for Borrego, • NAIOP SDA, General Electric, Omni-Navitas. GZA performed borings and test pits and • Mass Building Congress prepared geotechnical reports for concrete caissons for the carports.

Areas of Specialization • Solar Projects; Ground- mount/Carport • Multi-Story Building Foundations • Geotechnical Engineering • Foundation Engineering • Soil Characterization for Disposal • Soil Disposal • MCP-Oriented Construction • Geotechnical Instrumentation • Support of Excavation • Underpinning • Blasting

GZA . Known for excellence. Built on trust. Page | 1

BWF-PF1 Page 1 of 1

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT

______

PRE-FILED TESTIMONY OF:

CHRIS LOMIBAO

ROSENDIN

1730 S. ANAHEIM WAY, ANAHEIM, CA 92805

Case No. 17-F-0655 LOMIBAO

1 Q: Please state your name, employer, and business address.

2 A: Chris Lomibao, Rosendin, 1730 S. Anaheim Way, Anaheim, CA 92805.

3 Q: What is your position at Rosendin?

4 A: Director of Engineering, Renewables.

5 Q: How long have you been employed with Rosendin?

6 A: 6 years.

7 Q: Please describe your educational background and professional experience.

8 A: Electrical Engineering, 18 years of professional engineering experience, 13 years in renewables. A

9 copy of my resume is submitted as Exhibit ____ (CL-PF1): Resume of Chris Lomibao.

10 Q: Please describe your current responsibilities with Rosendin.

11 A: Direct, lead and mentor engineering staff for renewables engineering group at Rosendin.

12 Q: Have you previously testified before the New York State Public Service Commission or

13 Siting Board on Electric Generation?

14 A: No.

15 Q: Have you previously served as an expert witness before any other court, agency, or other

16 body on the subject you plan to offer testimony on today?

17 A: No.

18 Q: What is the purpose and scope of your testimony in this proceeding?

19 A: To sponsor certain portions of the Riverhead Solar 2 Application or the Exhibits thereto.

20 Q: What portion(s) of the Application is your testimony sponsoring?

21 A: The electrical design portion of the solar PV array, included as Appendices to Exhibits 5, 11, 18,

22 34, and 35.

Page 2 of 3

Case No. 17-F-0655 LOMIBAO

1 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

2 direction and supervision.

3 A: Under my direct supervision.

4 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

5 or documents produced by persons other than yourself/your company? If so, please cite

6 these sources.

7 A: Article 10 electrical array drawings produced by Fastgrid (outside consultant to Rosendin).

8 Article 10 Riverhead Solar 2, Electric and Magnetic Fields proposed by Power System Engineering

9 (outside consultant to Rosendin)

10 Article 10 substation expansion drawing set produced by HV group at Rosendin.

11 Article 10 civil drawings produced by Kimley Horn.

12 Q: Does this conclude your testimony?

13 A: Yes.

Page 3 of 3

With over 18 years of engineering experience, Chris leads the renewables, commercial and BIM Engineering team as the Chris Lomibao Director of Engineering, Southern California. As the Director, he REGIONAL DIRECTOR OF ENGINEERING, is responsible for the direction, planning, and management of all SOUTHERN CALIFORNIA engineering operations. In his tenure with Rosendin Electric, he has been responsible for the design of solar PV systems ranging Career Experience from small distributed generation systems to large utility scale Year Started with Rosendin: applications. Selection of major PV system design components 2014 starting from the solar PV modules all the way through the medium voltage components. Familiar and up to speed with all Year Started in Industry: 2007 of the trending technologies within the solar PV industry as well Education as energy modeling and estimation. Designed over 500MW of University of Michigan, BS - solar PV since 2007. Oversees and provides mentoring to junior Science Electrical Engineering engineers in the renewables Engineering Department. Licenses & Certifications SOLVERDE, Lancaster, CA Solar Energy International 2007, 106MW $80,669,389 Solar PV Design

ANTELOPE DSR1, Lancaster, CA Career Experience 62MW $45,889,445 Cell: 562.455.6976

BEACON SITE 1, Cantil, CA Office: 657.276.0627 56MW. $46,527,055 Email: [email protected] BEACON SITE 3, Cantil, CA 56MW. $45,848,273

BEACON SITE 4, Cantil, CA 50MW. $41,685,659

ELEVATION C, Lancaster, CA 40MW. $40,582,304

NORTH LANCASTER RANCH, Lancaster, CA 20MW. $17,613,445

SUMMER SOLAR, Lancaster, CA 20MW. $20,627,014

CENTRAL ANTELOPE DRY RANCH C, Lancaster, CA 20MW. $17,410,412

ANTELOPE BIG SKY RANCH, Lancaster, CA 20MW. $22,700,856

WABSRB, Lancaster, CA 20MW. $18,000,000

PERRYMAN SOLAR, Aberdeen, MD 13MW. $18,646,400

1 LOMIBAO, CHRIS

CL-PF1 Page 1 of 1 NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

DAVID M. HESSLER, P.E.

PRINCIPAL CONSULTANT, VICE-PRESIDENT

HESSLER ASSOCIATES, INC.

Case No. 17-F-0655 HESSLER

1 Q: Please state your name, employer, and business address.

2 A: David M. Hessler, Hessler Associates, Inc., 5096 N Silver Cloud Drive, St. George, UT 84770.

3 Q: What is your position at Hessler Associates?

4 A: Principal Consultant and Vice President.

5 Q: How long have you been employed with Hessler Associates?

6 A: I have been employed with Hessler Associates for 29 years.

7 Q: Please describe your educational background and professional experience.

8 A: I received a Bachelor of Science degree in Mechanical Engineering from the University of Maryland

9 and a Bachelor of Arts degree from the University of Hartford. I am a Professional Engineer (PE)

10 and a member of the Institute of Noise Control Engineering (INCE). As an acoustical engineer I

11 have 29 years of experience in the prediction, assessment, and mitigation of environmental noise

12 from new and existing power generation and industrial facilities. My current curriculum vitae is

13 attached as Exhibit ____ (DH-PF1) and provides a full history of my relevant professional experience,

14 including those cases where I have testified as an expert witness.

15 Q: Please describe your current responsibilities with Hessler Associates?

16 A: In my current position, I am primarily responsible for anticipating potential noise impacts from new

17 power generation facilities, recommending appropriate mitigation measures when necessary and

18 testing completed projects. I also diagnose noise issues at existing power plants and industrial

19 facilities and determine what practical mitigation options might be available to reduce noise.

20 Additionally, I act as an independent technical advisor to various state public utilities commissions

21 and review and evaluate permit applications for new power generation facilities.

22 Q: Have you previously testified before the New York State Public Service Commission or Siting

23 Board on Electric Generation?

Page 2 of 4

Case No. 17-F-0655 HESSLER

1 A: Yes. I provided written testimony on behalf of the Town of Fremont in the Baron Winds proceeding

2 (Case No. 15-F0122) and written testimony on behalf of the Mohawk Solar, LLC in the Mohawk Solar

3 proceeding (Case No. 17-F-0182).

4 Q: Have you previously served as an expert witness before any other court, agency, or other

5 body on the subject you plan to offer testimony on today?

6 A: Yes. I have testified in various matters and proceedings before the Office of the New York State

7 Attorney General, the Washington State Energy Facilities Siting Board, the Public Service

8 Commission of West Virginia, the Pennsylvania Department of Environmental Protection, the New

9 Hampshire Site Evaluation Committee, the Public Utilities Commission of Ohio, the Wisconsin Public

10 Service Commission, the South Dakota Public Utilities Commission, the Maine State Government

11 Energy, Utilities and Technology Committee, and the Rhode Island Energy Facility Siting Board.

12 Q: What is the purpose and scope of your testimony in this proceeding?

13 A: To sponsor certain portions of the Riverhead Solar 2 Application or the Exhibits thereto.

14 Q: What portion(s) of the Application is your testimony sponsoring?

15 A: I will be sponsoring the following Exhibits: Exhibit 19, Noise and Vibration and associated

16 appendices.

17 Q: Were these Exhibits, Application sections, or studies prepared by you or under your direction

18 and supervision.

19 A: Yes.

20 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data or

21 documents produced by persons other than yourself/your company? If so, please cite these

22 sources.

23 A: References are contained in Exhibit 19.

Page 3 of 4

Case No. 17-F-0655 HESSLER

1 Q: Does this conclude your testimony?

2 A: Yes.

Page 4 of 4

CURRICULUM VITAE

DAVID M. HESSLER

Title: Principal Consultant, Vice-President Hessler Associates, Inc.

Professional Affiliations: Professional Engineer (P.E.), Commonwealth of Virginia Member Institute of Noise Control Engineering (INCE) National Council of Acoustical Consultants (NCAC)

Education: Bachelor of Science in Mechanical Engineering (B.S.), 1997 Summa cum Laude A. James Clark School of Engineering University of Maryland, College Park, MD

Bachelor of Arts (B.A.), 1982 University of Hartford, Hartford, CT

Employer: Hessler Associates, Inc. 38329 Old Mill Way, Unit 8 Ocean View, DE 19970

Office Location: St. George, UT

Years in present position: 29

Current Job Description: Acoustical engineer specializing in the prediction, assessment and mitigation of environmental noise from new and existing power generation and industrial facilities. Typical tasks include:

• Field measurement studies of existing ambient sound levels in the vicinity of proposed project sites • Computer noise modeling of new facilities prior to construction • Environmental impact assessments for new projects • Noise mitigation design studies of new facilities • Verification measurements of completed facilities • Diagnostic studies of facilities with existing noise problems • Design and specification of noise mitigation measures • Educational lectures on noise issues for private corporations • Expert witness testimony

General Experience: As an outside consultant to nearly all the major power industry EPC contractors, developers and OEM’s, have been the principal acoustical designer of over 400 power plants and industrial facilities worldwide ranging from a 3900 MW power station in Saudi Arabia to numerous combustion turbine combined cycle plants, data centers, diesel generator installations, refineries and wind turbine projects. Typically, the focus of the work on these projects was to anticipate potential noise impacts at sensitive receptors near the project and recommend practical noise abatement measures to avoid them. In addition, extensive verification measurements in and around the completed power plants, industrial facilities and wind farms have been performed to confirm that the design recommendations have been successfully executed.

DH-PF1 Page 1 of 3

Representative Papers and Publications: “Wind Turbine Noise”, Chapter 7 Measuring and Analyzing Wind Turbine Sound Levels, Multi-Science Publishing Co., Brentwood, Essex, UK, Jan. 2012. Comprehensive book on all aspects of wind turbine noise. Each chapter written by a recognized expert in that subject.

Teleseminar “Wind Turbine Siting and Best Practices”, National Regulatory Research Institute (NRRI), Invited speaker, Jan. 2012.

“Best Practices Guidelines for Assessing Sound Emissions from Proposed Wind Farms and Measuring the Performance of Completed Projects”, Prepared for the Minnesota Public Utilities Commission under the auspices of the National Association of Regulatory Utility Commissioners (NARUC), Oct. 2011.

“Accounting for Background Noise when Measuring Operational Noise from Wind Turbines”, Fourth International Meeting on Wind Turbine Noise, Rome, Italy, Apr. 2011.

“Recommended noise level design goals and limits at residential receptors for wind turbine developments in the United States”, Noise Control Engineering Journal, J.59 (1), January-February 2011.

“Wind tunnel testing of microphone windscreen performance applied to field measurements of wind turbines”, Third International Meeting on Wind Turbine Noise, Aalborg, Denmark, June 2009.

“Experimental study to determine wind-induced noise and windscreen attenuation effects on microphone response for environmental wind turbine and other applications”, Noise Control Engineering Journal, J.56, July-August 2008.

Expert Witness Cases: Before the Washington State Energy Facilities Siting Board (EFSEC) on behalf of Bechtel and the Cherry Point Cogeneration Project, Bellingham, WA, 2003. Permitting support for a proposed combined cycle power plant facility.

Before the Public Service Commission of West Virginia on behalf of the Longview Power Project near Morgantown, WV, 2006. Permitting support for a proposed coal-fired power plant facility.

Before the Pennsylvania Department of Environmental Protection on behalf of Waste Management and the Alliance Sanitary Landfill in Taylor, PA, 2006. Support in defending against a Class Action Lawsuit brought by neighbors of the landfill.

Before the Office of the Attorney General of New York on behalf of the Hudson Valley Community College Cogeneration (Diesel) Plant. Support in defending against a Class Action Lawsuit brought by neighbors.

2 DH-PF1 Page 2 of 3

Before the Hanover County (VA) Board of Supervisors on behalf of Martin Marietta Materials and the Doswell Quarry, 2008. Permitting support for a proposed quarry expansion.

Before the New Hampshire Site Evaluation Committee on behalf of Granite Reliable Power, LLC, 2008. Permitting support for a proposed wind turbine project in Northern New Hampshire.

Before the Public Utilities Commission of Ohio, Ohio Power Siting Board on behalf of EverPower Renewables and the Buckeye Wind Project, 2008. Permitting support for a proposed wind turbine project in Ohio.

Before the Wisconsin Public Service Commission on behalf of Clean Wisconsin with regard to the proposed Highland Wind Farm in Forest, WI. Docket No. 2535-CE-100. Engaged as an independent expert to evaluate the Applicant’s sound studies and the testimony of opposition groups.

Before the Public Utilities Commission of Ohio, Ohio Power Siting Board on behalf of EverPower Renewables and the Buckeye II Wind Project, 2012. Permitting support for a proposed wind turbine project in Ohio.

Before the Maine State Government Energy, Utilities and Technology Committee on behalf of Patriot Renewables and the Beaver Ridge Wind Project, 2014. Peer review of operational sound testing by others.

Before the South Dakota Public Utilities Commission on behalf of the Commission Staff to review the noise aspects of the application for the Crocker Wind Farm Project. Docket EL17-055. April 2018.

Before the South Dakota Public Utilities Commission on behalf of the Commission Staff to review the noise aspects of the application for the Dakota Range Wind Project. Docket EL18-003. April 2018.

Before the Rhode Island Energy Facility Siting Board, serving as an outside expert to the Town of Burrillville, RI reviewing the noise aspects of the Clear River Energy Center permit application, Docket SB-2015-06, December 2018.

Before the South Dakota Public Utilities Commission, serving as an outside expert to the PUC Staff reviewing the noise aspects of the Deuel Harvest Wind Project permit application, Docket EL18-053, April 2019.

3 DH-PF1 Page 3 of 3

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

DENNIS JIMENO

TELECOMMUNICATIONS ENGINEER III,

COMSEARCH

Case No. 17-F-0655 JIMENO

1 Q: Please state your name, employer, and business address.

2 A: Dennis Jimeno, Comsearch, 19700 Janelia Farm Boulevard, Ashburn, VA 20147.

3 Q: What is your position at Comsearch?

4 A: I am a Telecommunications Engineer III.

5 Q: How long have you been employed with Comsearch?

6 A: I have been employed with Comsearch for about 17 years.

7 Q: Please describe your educational background and professional experience.

8 A: I have a Bachelor of Science degree in Electrical Engineering from Virginia Teach and a Master of

9 Science degree in Electrical Engineering from George Washington University. My entire professional

10 experience has been focused on the field of wireless network communications and microwave

11 engineering. From 1995 to 1998, I was employed by MLJ, Inc. as a Design Engineer. From 1998

12 to 2000, I worked as an RF Engineering Consultant for Nextel. I was employed as a Radio Frequency

13 (RF) Planning Engineer for Winstar from 2000 to 2001. From 2001 to 2004, I worked as an RF

14 Engineering Contractor for AT&T Cingular Wireless. Since then, I have been with Comsearch. A

15 copy of my resume is submitted as Exhibit __ (DJ-PF1): Resume of Dennis Jimeno.

16 Q: Please describe your current responsibilities with Comsearch.

17 A: At Comsearch, my current responsibilities include the planning, analysis, and optimization of wireless

18 communication and microwave networks for various applications. I supervise engineering studies to

19 assess the potential impact of solar and wind facilities on surrounding communications systems,

20 including microwave paths, mobile phone, over-the-air (OTA) television, AM/FM broadcast radio,

21 radar and land mobile radio. I provide technical expertise for various RF engineering projects with

22 respect to the design and deployment of wireless networks for terrestrial, maritime, and airborne

23 applications.

Page 2 of 4

Case No. 17-F-0655 JIMENO

1 Q: Have you previously testified before the New York State Public Service Commission or

2 Siting Board on Electric Generation?

3 A: I submitted pre-filed testimony to the New York State Public Service Commission on the Central

4 Hudson Gas and Electric Corporation’s Article VII Application for the A and C Line Rebuild Project.

5 Also, I have submitted pre-filed testimony to the Siting Board on Electric Generation in conjunction

6 with the Article 10 application for the Eight Point Wind Energy Project (16-F-0062), the Bluestone

7 Wind Energy Facility (Case No. 16-F-0559), the Deer River Wind Farm (Case No. 16-F-0267), and

8 the High Bridge Wind Project (Case No. 18-F-0262).

9 Q: Have you previously served as an expert witness before any other court, agency, or other

10 body on the subject you plan to offer testimony on today?

11 A: Yes, I served as an expert witness for the Freeborn Wind Project before the Minnesota Public

12 Utilities Commission, for the Lone Tree Wind Project before the Bureau County IL Zoning Board, and

13 for the Broad Mountain Wind Project before the Packer Township PA Zoning Board.

14 Q: What is the purpose and scope of your testimony in this proceeding?

15 A: To sponsor certain portions of the Riverhead Solar 2 Application or the Exhibits thereto.

16 Q: What portion(s) of the Application is your testimony sponsoring?

17 A: Exhibit 26, Effect on Communications.

18 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

19 direction and supervision.

20 A: Yes, Comsearch prepared impact assessment studies for certain communication systems on which

21 Exhibit 26 is based: Communications Tower Report, Land Mobile and Emergency Services, and a

22 Government Radar Systems Analysis.

Page 3 of 4

Case No. 17-F-0655 JIMENO

1 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

2 or documents produced by persons other than yourself/your company? If so, please cite

3 these sources.

4 A: References are provided in the Exhibits and associated Appendices.

5 Q: Does this conclude your testimony?

6 A: Yes.

Page 4 of 4

Dennis Jimeno Telecommunications Engineer III

QUALIFICATIONS

 Master of Science in Electrical Engineering  Experienced in RF Planning of wireless networks for ground, maritime, and airborne applications  Experienced in contract negotiations and managed multiple agreements between major wireless service provider and power utilities, municipalities and various communication companies in support of microwave relocation and wireless small-cell site deployment projects  Experienced in Microwave Path Engineering  Managed wind energy services group tasked with providing engineering studies to assess impact caused by wind energy facilities to surrounding communication systems including: microwave paths, mobile wireless, television, AM/FM radio, radar, and land mobile & emergency services  Experienced in evaluating compliance with FCC guidelines for human exposure to RF emissions  Experienced in analyzing drive test data to validate propagation model and optimize network performance  Formally trained in wireless networks, satellite communications, and signal propagation  Experienced in engineering software tools: Matlab, Atoll, SPLAT, CelPlan, Actix RPS and Mentum Planet  U.S. Citizen

PROFESSIONAL EXPERIENCE

Telecommunications Engineer III, Comsearch 2004 - Present Ashburn, VA

 Performed RF planning of Fixed Wireless Access (FWA) network using LTE technology in CBRS band

 Designed nationwide Environmental Sensing Capability (ESC) network to operate in conjunction with a Spectrum Access System (SAS) to enable sharing of 3.5 GHz frequency band between Citizens Broadband Radio Service (CBRS) and US Navy radar systems while minimizing interference  Performed RF Coverage and Frequency Planning for SCADA system in 900 MHz and 220 MHz bands for SmartGrid distribution of electricity  Engaged in discussions with various power utilities and municipalities to negotiate terms and conditions on behalf of AT&T to attach small cell equipment and antennas on utility poles nationwide  Reviewed, edited, and approved impact assessment studies of wind turbines with respect to microwave, radar, TV broadcast, AM/FM radio, and land mobile & emergency services  Designed ADS-B (Automatic Dependent Surveillance Broadcast) service volume coverage throughout U.S. airspace for FAA as part of NextGen program to modernize air transportation system  Generated ADS-B coverage predictions for ground-to-air and air-to-ground communications with primary objective of matching or exceeding Secondary Surveillance Radar (SSR) coverage from ground level up to 60,000 ft MSL  Performed link budget analyses to verify coverage for at least 98% of a given service volume in various interference conditions and scenarios using 1090ES and UAT links  Designed airport surface coverage using 3D ray-tracing model with task of covering 100% of surface movement area including glide approach path from five (5) nautical miles to touchdown threshold  Identified potential site locations using commercial towers, oil platforms, and public-use airport facilities that satisfied coverage objectives while minimizing interference to active radars  Performed power-flux density calculations from ADS-B stations to predict interference and satisfy conditional requirements to co-exist with surveillance radars and multi-lateration systems  Designed coverage layout for Automated Weather Observing System (AWOS) in Gulf of Mexico using oil platform locations  Reviewed and approved antenna configuration drawings prior to installation  Attended zoning hearings to seek board approval of permit to construct new cell sites  Performed RF hazard analysis per OET Bulletin 65 guidelines regarding safe RF exposure limits  Evaluated and approved site candidates for implementation

DJ-PF1 Page 1 of 3

Dennis Jimeno, Telecommunications Engineer III Page 2

 Designed E-911 networks for Tier I and Tier II Public Safety Access Points (PSAPs) using U-TDOA and AOA geo-location technology  Analyzed PCS and cellular network performance data to evaluate location accuracy performance and verify compliance with E-911 requirements  Defined drive-test routes for location accuracy testing and optimization

RF Engineering Contractor, AT&T / Cingular Wireless 2001 - 2004 Various locations

 Designed expansion sites for dual-band GSM network in NY/NJ market (Paramus, NJ) o Evaluated potential site candidates and performed site visits o Attended zoning hearings to seek board approval to install new antennas on existing towers o Tuned RF propagation model using drive test data o Analyzed drive test data to identify coverage-limited areas  Generated RF design for GSM network in south Florida market consisting of 400 sites (Lake Mary, FL) o Implemented overlay/underlay site designs using micro-cell solutions o Predicted FER performance for BCCH and TCH channels using Monte Carlo simulations o Performed link budget analyses and verified design ERP levels o Performed HSN and MAIO planning for frequency hopping algorithm o Managed network parameters using Nokia OSS/CM Tools and checked daily alarm reports o Performed on-air cell verification tests o Planned MSC, BSC and LAC boundaries  Generated GSM overlay design for existing TDMA network (Bothell, WA) o Optimized antenna configuration based on required number of TRXs per sector o Generated cell neighbor lists for optimized handoffs o Dimensioned BSCs according to current and projected traffic load  Designed WCS Fixed Wireless Network in 2.3 GHz band using OFDM technology (Dublin, OH) o Generated coverage predictions based on tuned propagation models using dB Planner tool o Processed drive test data and validated propagation models for 50 planned hubs o Analyzed drive test data to optimize coverage and minimize interference across network o Managed drive test team and coordinated daily activities to meet project milestones

RF Planning Engineer, Winstar 2000 - 2001 Herndon, VA

 Designed Point-to-Multipoint (PMP) fixed broadband wireless networks in 39 and 28 GHz bands  Predicted and analyzed interference between hub and subscriber locations  Performed coverage and capacity design trade-offs for PMP hubs for 64QAM, 16QAM, and QPSK modulation schemes  Performed link reliability and rain fade analyses using Crane model  Performed frequency planning  Evaluated RF software tools and recommended technical enhancements for site coverage planning  Performed field surveys to evaluate proposed site locations and verify radio line-of-sight (RLOS) conditions

RF Engineering Consultant, Nextel 1998 – 2000 Reston, VA

 Managed RF Engineering group in local market to design and optimize iDEN network (Mexico City)  Responsible for planning, roll-out optimization, and setting schedules milestones for project  Supervised frequency planning, capacity planning, and interference analysis  Approved search rings and site candidates  Optimized network parameters to meet key performance objectives for interconnect and dispatch services  Planned new cell sites to meet target expansion coverage and increase traffic capacity  Provided basic training on iDEN network optimization, design, and frequency planning  Led RF Engineering team to optimize iDEN network (White Plains, NY)  Performed frequency planning and interference analysis for 500+ sites for NY/NJ market  Optimized Interconnect Location Area (ILA) & Dispatch Location Area (DLA) boundaries DJ-PF1 Page 2 of 3

Dennis Jimeno, Telecommunications Engineer III Page 3

 Analyzed drive test data and tuned RF propagation models  Performed capacity analysis to project required number of base radios (BRs) per site

Design Engineer, MLJ Inc. 1995 – 1998 Arlington, VA

 Provided spectrum sharing engineering services for PCS service providers and incumbent microwave systems in 1.9 GHz band in support of microwave relocation efforts across U.S.  Performed interference analyses between PCS and microwave point-to-point systems to predict, rank, and mitigate co-channel and adjacent channel interference  Generated Prior Coordination Notices (PCNs)  Designed microwave point-to-point systems  Conducted field test measurements to calibrate RF propagation models  Performed CDMA optimization for cellular network (Phoenix, AZ)  Adjusted pilot channel powers to force dominant servers in areas with pilot pollution  Created neighbor lists for efficient handover  Performed idle-mode coverage and origination test drives to verify synch and paging channel operation  Adjusted and tuned search windows (e.g., active, candidate, neighbor, and remaining set) to utilize all good multipath components for optimal pilot selection  Analyzed drive test and post-test data including FER, Ec/Io, and variable Rx/Tx Power  Derived cell edge and area service reliability  Adjusted hand-off parameters including T-Comp, T-Add, Tt-Drop, and T-Drop  Performed troubleshooting test drives to analyze and resolve performance problems

EDUCATION

M.S., Electrical Engineering George Washington University, Washington, DC

B.S., Electrical Engineering Virginia Polytechnic Institute & State University, Blacksburg, VA

SOFTWARE

 RF Engineering: Atoll, Mentum Planet, Actix RPS, CelPlan, ATDI, Agilent Wizard, SPLAT  GIS Mapping: MapInfo, Esri ArcView  Programming: Matlab  Microwave Engineering: Pathloss, iQlinkXG

DJ-PF1 Page 3 of 3

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

DANIEL ZVIRZDIN

ENVIRONMENTAL DESIGN & RESEARCH,

LANDSCAPE ARCHITECTURE, ENGINEERING &

ENVIRONMENTAL SERVICES, D.P.C.

Case No. 17-F-0655 ZVIRZDIN

1 Q: Please state your name, employer, and business address.

2 A: Daniel Zvirzdin, Environmental Design & Research, Landscape Architecture, Engineering &

3 Environmental Services, D.P.C. (EDR), 217 Montgomery Street, Suite 1000, Syracuse, New York

4 13202.

5 Q: What is your position at EDR?

6 A: I am a Senior Environmental Analyst at EDR.

7 Q: How long have you been employed with EDR?

8 A: I have been employed by EDR since 2018.

9 Q: Please describe your educational background and professional experience.

10 A: I received a Bachelor of Science, Wildlife and Wildlands Conservation, from Brigham Young

11 University in 2010. I received a Master of Science, Wildlife and Wildlands Conservation, from

12 Brigham Young University in 2012 and am a published author in the fields of Soil Science, Ecology,

13 and Remote Sensing. Additional information on my experience is presented in my resume, which is

14 included Exhibit ___ (DZ-PF1): Resume of Daniel Zvirzdin.

15 Q: Please describe your current responsibilities with EDR.

16 A: As a Senior Environmental Analyst with EDR, I work directly with clients and project managers in

17 developing projects, completing environmental analyses, processing data, preparing technical

18 reports, and packaging final products. I also prepare permitting materials, conduct wetland

19 delineations, participate in meetings with the public and government agencies, develop, analyze,

20 and summarize field and GIS data, and serve as a quality control manager for outgoing materials.

21 Q: Have you previously testified before the New York State Public Service Commission or

22 Siting Board on Electric Generation?

Page 2 of 3

Case No. 17-F-0655 ZVIRZDIN

1 A: I have previously provided written rebuttal testimony and was an expert witness in the matter of

2 Bluestone Wind LLC’s Application for a Certificate of Environmental Compatibility and Public Need

3 (Case No. 16-F-0559).

4 Q: Have you previously served as an expert witness before any other court, agency, or other

5 body on the subject you plan to offer testimony on today?

6 A: No.

7 Q: What is the purpose and scope of your testimony in this proceeding?

8 A: To sponsor certain portions of the Riverhead Solar 2 Project Application or the Exhibits thereto.

9 Q: What portion(s) of the Application is your testimony sponsoring?

10 A: Exhibit 28: Environmental Justice.

11 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

12 direction and supervision.

13 A: Yes.

14 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

15 or documents produced by persons other than yourself/your company? If so, please cite

16 these sources.

17 A: References, if any, are listed in the Exhibits and accompanying Appendices identified above.

18 Q: Does this conclude your testimony?

19 A: Yes.

Page 3 of 3

Daniel Zvirzdin Senior Environmental Analyst

Daniel Zvirzdin is a Senior Environmental Analyst at EDR with more than 10 years of professional experience. Daniel previously worked in academia as a Research Project Manager and for the Bureau of Land Management as a Rangeland Management Specialist. Daniel has a strong background in soil and plant ecology, environmental permitting and planning, technical writing, and land management. He is a published author in the fields of Soil Science, Ecology, and Remote Sensing, and is the lead author on several NEPA documents.

As a Senior Environmental Analyst with EDR, Daniel works directly with clients and project managers in developing projects, completing environmental analyses, processing data, preparing technical reports, and packaging final products. Daniel also prepares permitting materials, conducts wetland delineations, participates in meetings with the public and government agencies, develops, analyzes, and summarizes field and GIS data, and serves as a quality control manager for outgoing materials.

project experience

High Bridge Wind Project, Chenango County, NY – Authored the Public Involvement Program Plan (PIP), the Preliminary, Revised, and Final Scoping Statements, and many of the exhibits in the Article 10 Application. Conducted final quality control revisions to Application materials, developed many of the figures and conducted all education impact calculations. Participated in open houses, Stipulations discussions, and other meetings with the public, government agencies, and other interested parties. Coordinated project field work (e.g., wetland delineations, Bachelor of Science, Wildlife and receptor surveys, stone feature surveys, archaeological shovel testing, field water well verification, etc.), and Wildlands Conservation, Brigham served as the technical lead for the project. Completed the following tasks during the post-Application phase of the Young University, 2010. Article 10 process: prepared the Application Supplement and the Deficiency Response Letter and assisted in preparing responses to Interrogatory Requests. Master of Science, Wildlife and Wildlands Conservation, Brigham Bluestone Wind Project, Broome County, NY – Authored multiple exhibits and served as the technical editor for Young University, 2012. the Article 10 Application. Conducted shadow flicker analysis field work and prepared all GIS analyses for upland impacts. Completed the following tasks during the post-Application phase of the Article 10 process: developed and employment history submitted responses to Interrogatory Requests (IRs), co-authored the Application Update, worked with counsel in drafting a Joint Proposal for Settlement, Certificate Conditions, and a Site Engineering and Environmental Plan Senior Environmental Analyst, (SEEP), developed the Tree Clearing Plan and Revised Joint Application for Permit and Request for Water Quality Environmental Design & Research, Certification, coordinated site visits with project BOP contractors, and participated in numerous conferences and Landscape Architecture, Engineering settlement meetings with the public, government agencies, and other interested parties. & Environmental Services, DPC, Syracuse, NY, 2018-present. Morris Ridge Solar Project, Livingston County, NY – Served as the technical lead in supporting the production of the Article 10 Application. Worked with the client and project engineer in refining the civil design and developing the Rangeland Management Specialist, solar glare hazard assessment. Produced and/or coordinated the production of many of the exhibits and supporting Bureau of Land Management, studies. Conducted final technical reviews of most Application materials. Department of the Interior, Elko, NV,

2013- 2018. Mohawk Solar Project, Montgomery County, NY – Performed environmental impact assessments and analyses Soil and Plant Research Project to support the preparation of the Article 10 Application. Authored multiple exhibits, provided quality control and review Manager. Brigham Young University. of reports and studies, led various GIS mapping efforts. Provo, UT, 2010-2013. Riverhead 2 Solar Project, Suffolk County, NY – Led the Environmental Justice analysis and produced and/or Research Assistant, Dr. Steven coordinated the production of several of the exhibits, supporting environmental analyses, and figures for the Article Petersen, Provo, UT, 2008-2010. 10 Application.

Dormant Season of Use Programmatic Environmental Assessment – District Office lead in document preparation, planning, and technical analysis.

O’Neil Project Planning Area Environmental Assessment – Field Office lead in development, document preparation, and technical oversight.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

DZ-PF1 Page 1 of 2

Daniel Zvirzdin Senior Environmental Analyst

Publications

Zvirzdin, D.L., Roundy, B.A., Barney, N.S., Petersen, S.L., Anderson, V.J. and Madsen, M.D., 2017. Postfire soil water repellency in piñon–juniper woodlands: Extent, severity, and thickness relative to ecological site characteristics and climate. Ecology and Evolution 7:4630-4639.

Madsen, M. D., Zvirzdin, D. L., Petersen, S. L., Hopkins, B. G., & Roundy, B. A. 2015. Anchor chaining’s influence on soil hydrology and seeding success in burned piñon-juniper woodlands. Rangeland Ecology & Management, 68: 231-240.

Madsen, M., Zvirzdin, D.L., Roundy, B., and Kostka, S. 2014. Improving reseeding success after catastrophic wildfire with surfactant seed coating technology. In Pesticide Formulation and Delivery Systems: 33rd Volume, “Sustainability: Contributions from Formulation Technology”. ASTM International.

Zvirzdin, D.L. 2012. Post-fire soil water repellency: extent, severity and thickness relative to ecological site characteristics within piñon-juniper woodlands. Thesis. Brigham Young University, Provo, Utah. 31 p.

Madsen, M., Kostka, S., Inouye, A., Zvirzdin, D.L. 2012. Post-fire Restoration of Soil Hydrology and Wildland Vegetation using Surfactant Seed Coating Technology. Rangeland Ecology and Management 65:253-259.

Madsen, M.D., Zvirzdin, D.L., Davis, B.D., Petersen, S.L., and Roundy, B.A. 2011. Feature extraction techniques for measuring piñon and juniper tree cover and density, and comparison with field based management surveys. Environmental Management 47:766-776.

Madsen, M.D., Zvirzdin, D.L., Petersen, S.L., Hopkins, B.G., Roundy, B.A., and Chandler, D.G. 2011. Soil water repellency within a burned piñon-juniper woodland: spatial distribution, severity, and ecohydrologic implications. Soil Science Society of America Journal 75:1543-1553.

Davies, KW., Petersen, S.L., Johnson, D.D., Davis, D.B., Madsen, M.D., Zvirzdin, D.L., and Bates, J.L. 2010. Estimating western juniper cover with NAIP imagery and evaluating the relationships between potential cover and environmental variables. Journal of Rangeland Ecology & Management 63:630-637.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

DZ-PF1 Page 2 of 2

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF

ERICA TAUZER

PROJECT MANAGER

ENVIRONMENTAL DESIGN & RESEARCH

LANDSCAPE ARCHITECTURE, ENGINEERING &

ENVIRONMENTAL SERVICES, D.P.C.

Case No. 17-F-0655 TAUZER

1 Q: Please state your name, employer, and business address.

2 A: Erica Tauzer, Environmental Design & Research, Landscape Architecture, Engineering &

3 Environmental Services, D.P.C. (EDR), 217 Montgomery Street, Suite 1000, Syracuse, New York

4 13202.

5 Q: What is your position at EDR?

6 A: Project Manager.

7 Q: How long have you been employed with EDR?

8 A: I have been employed at EDR since 2015.

9 Q: Please describe your educational background and professional experience.

10 A: I received a Bachelor of Arts Degree in Biology and Spanish from Albion College and a Master of

11 Science in Environmental Studies from the State University of New York College of Environmental

12 Science and Forestry. Since joining EDR, I have worked on a variety of projects as a land use and

13 community planning professional, including: researching and drafting waterfront revitalization plans,

14 agricultural and farmland protection plans, comprehensive plans, and other local plans and reports;

15 coordinating outreach meetings and events; and grant writing. As discussed below, I have also

16 prepared socioeconomic and other analyses for wind and solar projects in New York and Ohio. Prior

17 to joining EDR, I worked as Research Coordinator with the State University of New York Upstate

18 Medical Center & Ecuador’s Secretory of Risk Management on research relating to flooding

19 response, vulnerability, and adaptive capacity. A copy of my resume is submitted as Exhibit ____

20 (ET-PF1): Resume of Erica Tauzer.

21 Q: Please describe your current responsibilities with EDR.

22 A: As a Project Manager at EDR, I am responsible for project coordination, technical research, and

23 drafting reports and meeting materials relating to land use and community planning projects,

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Case No. 17-F-0655 TAUZER

1 including local waterfront revitalization plans, comprehensive plans, zoning reviews, and agricultural

2 economic development/farmland protection plans. In addition, I coordinate and lead project-related

3 community outreach meetings and events and manage the development of outreach materials. I am

4 also responsible for conducting socioeconomic analyses of utility-scale wind and solar energy

5 projects and preparing the exhibits and reports to be submitted with the applications to the state.

6 Q: Have you previously testified before the New York State Public Service Commission or Board

7 on Electric Generation Siting and the Environment (“Siting Board”)?

8 A: Yes, I submitted pre-filed testimony in the proceedings related to the High Bridge Wind Project (Case

9 No. 18-F-0262), the Mohawk Solar Facility (Case No. 17-F-0182), the Heritage Wind Project (Case

10 No. 16-F-0546), and the Flint Mine Solar Project (Case No. 18-F-0087).

11 Q: Have you previously served as an expert witness before any other court, agency, or other

12 body on the subject you plan to offer testimony on today?

13 A: No.

14 Q: What is the purpose and scope of your testimony in this proceeding?

15 A: To sponsor or co-sponsor certain portions of the Riverhead Solar 2 Application and the Exhibits

16 thereto.

17 Q: What portion(s) of the Application is your testimony sponsoring?

18 A: Exhibit 4: Land Use and Exhibit 27: Socioeconomic Effects.

19 Q: Were these Exhibits, Application sections, or studies prepared by you or under your direction

20 and supervision.

21 A: Yes.

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Case No. 17-F-0655 TAUZER

1 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data or

2 documents produced by persons other than yourself/your company? If so, please cite these

3 sources.

4 A: See Exhibits 4 and 27 for any references.

5 Q: Does this conclude your testimony?

6 A: Yes.

Page 4 of 4

Erica Tauzer, AICP Project Manager

Erica is a Project Manager at EDR with more than 6 years of professional experience in land use and community planning. She has worked with communities across the state to plan for change, understand existing data, and develop solutions for local and regional needs and long-term goals. In her time at EDR, Erica has worked on a variety of projects, including waterfront revitalization plans, socioeconomic analyses, farmland protection plans, public outreach initiatives, environmental resource inventories, grant writing, and many more. She has worked with a wide range of communities—from metropolitan areas to rural towns and villages—to suit the needs of her client and their funding entities. As a Project Manager with EDR, Erica’s responsibilities include project coordination, technical research, writing and report layout for planning reports, grant writing, and socioeconomic and land use analyses for large scale renewable energy projects in New York and Ohio. She has coordinated and led project-related community outreach meetings/events and has managed the development of outreach materials. She has participated actively in project-related meetings and has managed the research required for renewable energy project applications in New York and Ohio as well as municipal plans and New York State specific planning programs, including the Local Waterfront Revitalization Program, Downtown Revitalization Initiative, Hazard Mitigation Plans, and the Lake Ontario Resiliency and Economic Development Initiative. education employment history Master of Science, Environmental Studies, State University of New York Project Manager, Environmental Design & Research, Landscape College of Environmental Science & Forestry, 2014. Architecture, Engineering & Environmental Services, D.P.C, Syracuse, NY, 2020-present. Bachelor of Arts, Biology & Spanish, Albion College, 2010. Senior Planner, Environmental Design & Research, Landscape Advanced Studies, Universidad Autónoma de Yucatán, College of Architecture, Engineering & Environmental Services, D.P.C, Anthropology, 2009. Syracuse, NY, 2019-2020. registration / certifications Planner, Environmental Design & Research, Landscape Architecture, Engineering & Environmental Services, D.P.C, American Institute of Certified Planners, American Planning Association Syracuse, NY, 2015-2019. Certification of Advanced Study in Conflict Resolution, Program for Research Coordinator, State University of New York Upstate Medical the Advancement of Research on Conflict and Collaboration, & Ecuador’s National Secretary of Risk Management, Syracuse, NY, Syracuse University. 2014-2015. Community-Based Research Ethics, Northeast Ethics Education Research Fellow & Teaching Assistant, State University of New York Partnership, Brown University. College of Environmental Science & Forestry, Courses: Environmental Decision-Making, Policy & History, Syracuse, NY, professional afiliations 2011-2014 Member, American Planning Association Project Coordinator, East Side Neighborhood Services & Public Member, Board of Directors, New York State APA – CNY Section Allies, Minneapolis, MN, 2010-2011. project experience

Renewable Energy Permitting in New York- Prepared sections of applications submitted under Article 10 of the New York Public Service Law analyzing the socioeconomic and land use impacts of large-scale renewable energy projects, and conducted public information meetings, including the first such application submitted statewide. Projects include: Morris Ridge Solar Facility, Livingston County, NY- Conducted socioeconomic analysis and prepared Exhibit 27 for a proposed utility-scale solar power facility as part of an Article 10 application. Riverhead 2 Solar Facility, Suffolk County, NY- Conducted socioeconomic analysis and prepared Exhibit 27 for a proposed utility-scale solar power facility as part of an Article 10 application. Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

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Erica Tauzer, AICP Project Manager

Flint Mine Solar Facility, Greene County, NY- Conducted socioeconomic analysis and prepared Exhibit 27 for a proposed utility-scale solar power facility as part of an Article 10 application. Heritage Wind Project, Orleans County, NY- Conducted socioeconomic analysis and prepared Exhibit 27 for a proposed 33-turbine commercial wind power facility as part of an Article 10 application. Mohawk Solar Project, Montgomery County, NY- Conducted socioeconomic and land use analysis and prepared Exhibit 4, Exhibit 27 and accompanying socioeconomic report as part of an Article 10 application. High Bridge Wind Project, Chenango County, NY- Conducted socioeconomic analysis and prepared socioeconomic report and Exhibit 27 for a proposed 25-turbine commercial wind power facility as part of an Article 10 application. Baron Wind Project, Steuben County, NY- Conducted socioeconomic analysis and prepared Exhibit 27 and accompanying socioeconomic report for a proposed 76-turbine commercial wind power facility as part of an Article 10 application. Bluestone Wind Project, Broome County, NY- Conducted socioeconomic analysis and prepared socioeconomic report and Exhibit 27 for a proposed 33-turbine commercial wind power facility as part of an Article 10 application. Galloo Island Wind Project, Jefferson County, NY- Conducted socioeconomic analysis and prepared socioeconomic report and Exhibit 27 for a proposed 30-turbine commercial wind power facility and associated offshore transmission line as part of an Article 10 application. Cassadaga Wind Project, Chautauqua County, NY- Conducted socioeconomic analysis and prepared the socioeconomic report and Exhibit 27 for a proposed 62-turbine commercial wind power project as part of an Article 10 application. Renewable Energy Permitting in Ohio- Prepared socioeconomic reports for applications to the Ohio Power Siting Board (OPSB) for commercial scale wind and solar power projects. In accordance with the Ohio Administrative Code, the certification applications addressed potential project-related impacts to ecological resources, soils and geology, groundwater, air quality, aesthetics, agricultural land use, cultural resources, and socioeconomics. All applications have been accepted as complete after initial submittal. Projects include: Powell Creek Solar Facility, Putnam County, OH- Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB. Arche Solar Facility, Fulton County, OH- Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB. Yellowbud Solar Facility, Pickaway and Ross Counties, OH Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB. Republic Wind Farm, Seneca and Sandusky Counties, OH- Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB.

Emerson Creek Wind Farm and Transmission Line, Erie and Huron Counties, OH- Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB.

Timber Road IV Wind Farm and Transmission Line, Paulding County, OH- Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB. Hillcrest Solar Project, Brown County, OH- Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB. Project Icebreaker, Erie County, Cleveland, OH- Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB. Local Waterfront Revitalization Plan, Town & Village of Cape Vincent, NY (in progress)- Completed research and report writing for local planning initiative examining land use and development considerations along land resources adjacent to the St. Lawrence River and Lake Ontario in this northern Jefferson County community. Interfaced with intermunicipal project leadership to advance priority waterfront ecological, recreational and economic

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

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Erica Tauzer, AICP Project Manager

development initiatives within the project area, consistent with the requirements of the New York State Department of State (NYSDOS) Local Waterfront Revitalization Program. Great Lakes Restoration Initiative Eurasian Milfoil Control, Town of Alexandria, NY (in progress)- Project coordination and management for the Alexandria Milfoil Task Force, a group composed of municipal employees and local volunteers. The GLRI grant was awarded to the Town through the US Environmental Protection Agency. Local Waterfront Revitalization Plan, Town of DeWitt, NY (in progress)- Completed research and report writing for local planning initiative examining land use and development considerations relating to land resources adjacent to the Erie Canal and Butternut Creek in this first-ring suburban community. Interfaced with intermunicipal project leadership to advance priority waterfront ecological, recreational and economic development initiatives within the project area, consistent with the requirements of the NYSDOS Local Waterfront Revitalization Program. I-81 Viaduct Project, New York State Department of Transportation, Syracuse, NY, (in progress)- Supported community outreach efforts pursuant to federal National Environmental Policy Act (NEPA) and New York State Environmental Quality Review Act (SEQRA). Assisted with planning and execution of meetings ranging from small group discussions to large public open house meetings. Coordinated mailings and email communications and outreach to individual stakeholders, and researched local issuses. Represented project at various community events, including a weekly informational visitor center. Comprehensive Plan, Village of Trumansburg, NY - Served as Community Planner for team that researched existing conditions and analyzed economic and demographic changes over time. Worked with local advisory committee to craft goals and recommended actions for plan implementation. Designed interactive activities and staffed community workshop to gather local perspectives at each stage of the planning process. Hazard Mitigation Plan, Onondaga County, NY - Served as Community Planner for team that researched local hazard data for several municipalities across Onondaga County. Staffed and coordinated workshop with local municipal leaders designed to finalize profiles describing local vulnerabilities and preparedness, response, and recovery systems. Worked with local officials to craft hazard mitigation project descriptions. Assisted project team with the preparation of final report. ReZone Syracuse, City of Syracuse, NY- Supported City of Syracuse’s effort to draft a substantial revision to the municipal zoning code through the NYS Brownfield Opportunity Areas program. Assisted in parcel and district mapping. Update of County Agricultural Economic Development Plan, Broome County, NY- Assisted with the development of the County Agricultural Economic Development Plan update in order to provide the Broome County with a strategic and focused guide to promote the sustainable preservation of agriculture lands through the analysis of lands vulnerable to development and resilient to natural disasters. Funding was provided by a New York State Agriculture and Farmland Protection Program Grant. Agricultural and Farmland Protection Plan, Ontario County, NY- Conducted research on the county’s agricultural development and farmland protection plan, funded through a Farmland Protection Planning grant from NYS Department of Agriculture & Markets. Drafted and implemented a public involvement initiative, including focus group discussions, community events, public meetings, and social media campaign. Inventoried existing conditions of the agricultural sector throughout Ontario County, including production statistics, labor and economic indicators, identification of essential support businesses, and a summary of local environmental management programs. Managed weighted geospatial analysis for the identification of priority lands for protection and other implementation efforts. Agricultural and Farmland Protection Plan Update, Montgomery County, NY- Served as community planner for the Agricultural and Farmland Protection Plan that identified key issues facing agriculture in the community, conducted agricultural suitability analysis for parcels which guided the development of recommended strategies for capitalizing on advantages and overcoming barriers, and advanced the viability of farming as an enterprise and a way of life on behalf of Montgomery County. Managed weighted geospatial analysis for the identification of priority lands for protection and other implementation efforts. The purpose of the planning for agriculture is to maintain the quality and accessibility of the sector’s primary natural and economic resources. Smart Growth Update and Implementation Project, Town of Marcy, NY- Analyzed land use change and development within this first-ring suburb since the adoption of its existing Master Plan, funded through a grant from the NYSERDA Cleaner Greener Communities program. Assessed development potential of land throughout residential and commercial areas using ArcGIS, and recommended methods for protection of rural character in outlying areas. Downtown Revitalization Initiative (DRI), Village of Potsdam, NY- Managed community engagement efforts to gain public input on proposed DRI Projects in coordination with the lead consultant and Village Local Planning Committee for submittal to New York State as part of $10 million downtown revitalization grant awarded to the Village.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 3 www.edrdpc.com

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Erica Tauzer, AICP Project Manager

Downtown Revitalization Initiative (DRI), City of Cortland, NY- Assisted with the public presentation of sections of DRI Priority Projects in coordination with the City’s Local Planning Committee for submittal to New York State as part of $10 million downtown revitalization grant awarded to the City. Downtown Revitalization Initiative (DRI), Round 2, City of Elmira, NY- Assisted with the preparation of sections of DRI Final Report on Priority Projects in coordination with the City’s Local Planning Committee for submittal to New York State as part of $10 million downtown revitalization grant awarded to the City. Downtown Revitalization Initiative), City of Saranac Lake, NY- Assisted with the public presentation of sections of DRI Final Report on Priority Projects in coordination with the City’s Local Planning Committee for submittal to New York State as part of $10 million downtown revitalization grant awarded to the City. Comprehensive Plan, Town of Ovid, NY - Served as Community Planner for team that researched existing conditions and analyzed economic and demographic changes over time. Worked with local advisory committee to craft goals and recommended actions for plan implementation. Designed interactive activities and staffed community workshop to gather local perspectives at each stage of the planning process. Multiple Dwellings Study, Town of Henrietta, NY- Provided expertise related to geographic analysis of existing zoning districts and regulations and possible zoning amendments related to smart growth and mixed-use dwellings within the Town of Henrietta. Grant writing- Supported communities in seeking grants for public funds through New York State and federal sources. Specific grant experience with the Great Lakes Restoration Initiative (USEPA), Local Waterfront Revitalization Program (NYSDOS), and New York State Department of Environmental Conservation (NYSDEC) Invasive Species Control and Response grants. Watershed Management Plan, Owasco Lake, Cayuga County, NY- Designed and implemented a survey on visitor goals, concerns and activities regarding Owasco Lake, while conducting outreach and education about the Owasco Lake Watershed Management Planning process. EDR designed and facilitated a community outreach plan with the goal of engaging local residents, agricultural producers and educators around shared visions, goals and concerns relating to the future of the Owasco Lake Watershed, as part of the Owasco Lake Watershed Management Plan. Transit Study Phase 1 (on behalf of the Central New York Regional Transportation Authority), Syracuse Metropolitan Regional Transportation Authority, Syracuse, NY- Assisted the EDR team responsible for providing locally-based community planning and community outreach/ engagement services, with a team of national consultants, to advance recommendations identified in the Syracuse Transit Study Analysis to pursue higher-intensity transit services along the DestinyUSA/Regional Transportation Center to Syracuse University and James Street/South Avenue corridors. Local Waterfront Revitalization Program (LWRP), NYS Department of State (NYSDOS), Town of Alexandria & Village of Alexandria Bay, NY- Conducted background research and grant writing needed for the continuation of tasks outlined by the LWRP process, specifically sidewalk renovations, dock improvements and streetscaping enhancements. Through the waterfront revitalization program, the village and town, with assistance from EDR, has identified a clear vision with supporting strategies to revitalize the waterfront by rehabilitating historic structures and improving waterfront resources. Cornell Cooperative Extension- Prior to EDR- Served as a Forestry Educator and managed tree planting database and site selection for urban tree plantings for the City of Syracuse as part of the Save the Rain program. Coordinated neighborhood volunteer tree planting and special events with the Onondaga Earth Corps. Promoted urban forestry maintenance through educational trainings with CommuniTree Stewards. SUNY Upstate Medical University & Ecuador’s National Secretary of Risk Management- Prior to EDR, Developed and implemented research on flooding response vulnerability and capacity. Coordinated project in collaboration with local, national and international stakeholders related to flood response. Supervised team of students, professors and local authorities to implement research methods. SUNY Upstate Medical University & U.S. Department of Defense- Prior to EDR, Led local capacity training efforts related to geographic information systems in epidemiological studies. Coordinated two 50-person GIS workshops and learning networks for public health practitioners in Machala and Guayaquil, Ecuador. Provided field and logistical support for cholera global surveillance project. SUNY ESF- Prior to EDR, Served as a Research Fellow in partnership with the NYSDEC. Utilized qualitative and quantitative analysis with questionnaires and interview data to inform the Natural Resources Damages Assessment and Restoration process for Onondaga Lake and its watershed. Topics included integrative policy analysis, procedural justice, place attachment, and ecological restoration. Program for Advancement of Research on Conflict & Collaboration- Prior to EDR, Co-facilitated Onondaga Lake Watershed Community Forums on decisions related to future restoration visions.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 4 www.edrdpc.com

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Erica Tauzer, AICP Project Manager

Mid-Atlantic Regional Ocean Council (MARCO)- Prior to EDR, Consultant- Designed adaptive management and stakeholder outreach plan for coastal off-shore wind development in the Mid-Atlantic region. NYS Department of Environmental Conservation- Prior to EDR, Implemented face to face surveys of recreational boating and fishing use at Onondaga Lake. Supervised team of four graduate and four undergraduate students. East Side Neighborhood Services & Public Allies, Minneapolis, MN- Prior to EDR, Initiated and implemented two intergenerational environmental programs and community vegetable gardens. Developed website, co-planned three fundraiser events, prepared outreach materials, and supervised intern. Co-developed an asset-based community development afterschool program in collaboration with Boys & Girls Club. U.S. Institute of Environmental Conflict Resolution- Prior to EDR, Served as a Udall Scholar Intern. Supported the development and implementation of training on Government-to-Government consultation. Assisted with environmental mediator hiring processes, wrote case briefings on collaborative planning processes for public lands, and fulfilled administrative duties related to stakeholder collaborative processes and conference planning. Michigan Student Sustainability Coalition- Prior to EDR, Served as the Albion College Representative and organized three statewide press events to promote awareness on climate change and energy policy in Michigan. Paso Pacífico, Southwestern Nicaragua- Prior to EDR, Assisted with work relating to community-based agriculture, cooperatively-structured business development, and sea turtle conservation in Southwestern Nicaragua. Provided translation services to United Nations Environmental Programme and USAID representatives Cary Institute of Ecosystem Studies, National Science Foundation, Baltimore, MD- Prior to EDR, Conducted and designed independent research on the urban ecology of vacant lots in Baltimore to determine the role of vacant lots in habitat creation and ecological resiliency. Presented information at the annual conference for the Baltimore Ecosystem Study, a collaboration between academic researchers, nonprofits, and the City of Baltimore Parks Department. National Wildlife Federation, Albion, MI- Prior to EDR, Prepared and presented greenhouse gas inventory calculating the carbon emissions at Albion College. Co-founded and facilitated Albion Sustainability Council devoted to promoting sustainable practices on campus and within City government. Presented results at two student research symposiums at Albion College and City Council meeting. publications

Tauzer, E.C., Borbor-Cordova, M.J. Mendoza, J., De La Cuadra, T., Cunalata, J., Stewart-Ibarra, A.M. (2019) A participatory community case study of periurban coastal flood vulnerability in southern Ecuador. PLOS ONE Urban Ecosystems Collections. Tauzer, E.C. (2014) An Integrative Analysis of Place and Participation: Onondaga Lake, NY. Summary Report for NY Department of Environmental Conservation and all research participants and interested stakeholders. Johnson, A. L., Tauzer, E. C., Swan, C. M. (2014), Human legacies differentially organize functional and phylogenetic diversity of urban herbaceous plant communities at multiple spatial scales. Applied Vegetation Science.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 5 www.edrdpc.com

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NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF

GORDON W. PERKINS

SENIOR PROJECT MANAGER

ENVIRONMENTAL DESIGN & RESEARCH

LANDSCAPE ARCHITECTURE, ENGINEERING &

ENVIRONMENTAL SERVICES, D.P.C.

Case No 17-F-0655 PERKINS

1 Q: Please state your name, employer, and business address.

2 A: Gordon Perkins, GISP, Environmental Design & Research, Landscape Architecture, Engineering &

3 Environmental Services, D.P.C. (EDR), 217 Montgomery Street, Suite 1000, Syracuse, New York

4 13202.

5 Q: What is your position at EDR?

6 A: Senior Project Manager/Visualization Specialist.

7 Q: How long have you been employed with EDR?

8 A: I have been employed at EDR since July 2016. I previously worked for EDR from 2001 through 2008.

9 Q: Please describe your educational background and professional experience.

10 A: I have a Bachelor of Landscape Architecture from the State University of New York College of

11 Environmental Science and Forestry, and am a Certified Geographic Information Systems

12 Professional (GISP). I have more than 18 years of professional experience focusing primarily on

13 visualization and visual impact assessment, with extensive expertise in two-dimensional (2-D) and

14 three-dimensional (3-D) visualization tools used in visual impact assessment. A copy of my resume

15 is submitted as Exhibit ____ (GWP-PF1): Resume of Gordon W. Perkins.

16 Q: Please describe your current responsibilities with EDR.

17 A: As a Senior Project Manager/Visualization Specialist, I am responsible for conducting and/or

18 overseeing all of the firm’s visualization projects, including visual impact assessments. I also oversee

19 and direct the ongoing advancement of EDR’s visualization capabilities and technical methodologies,

20 including new techniques in data collection, processing, and analysis and 3-D modeling. I am also

21 responsible for assigning, scheduling and coordinating staff, overseeing project teams, and providing

22 quality assurance.

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Case No 17-F-0655 PERKINS

1 Q: Have you previously testified before the New York State Public Service Commission or Siting

2 Board on Electric Generation?

3 A: Yes. I have provided testimony on the following cases: 13-T-0292 - West Point Power Partners, 06-

4 T-0650 - New York Regional Interconnection, 16-F-0205 – Canisteo Wind Energy LLC, and 17-F-

5 0282 - Alle-Catt Wind Energy LLC. In addition, I have submitted pre-filed testimony in conjunction

6 with the Bluestone Wind Energy Facility (Case No. 16-F-0559), the Galloo Island Wind Energy

7 Facility (Case No. 15-F-0327), the Heritage Wind Energy Facility (Case No.16-F-0546), and the High

8 Bridge Wind Energy Facility (Case No. 18-F-0262).

9 Q: Have you previously served as an expert witness before any other court, agency, or other

10 body on the subject you plan to offer testimony on today?

11 A: I have provided expert witness testimony before the Rhode Island Energy Facilities Siting Board, the

12 Connecticut Siting Council, and the Maryland Public Service Commission.

13 Q: What is the purpose and scope of your testimony in this proceeding?

14 A: To sponsor certain portions of the Riverhead Solar 2 Project Application or the Exhibits thereto.

15 Q: What portion(s) of the Application is your testimony sponsoring?

16 A: Exhibit 24, Visual Impacts.

17 Q: Were these Exhibits, Application sections, or studies prepared by you or under your direction

18 and supervision.

19 A: Yes.

20 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data or

21 documents produced by persons other than yourself/your company? If so, please cite these

22 sources.

23 A: See Exhibit 24 for references.

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Case No 17-F-0655 PERKINS

1 Q: Does this conclude your testimony?

2 A: Yes.

Page 4 of 4

Gordon Perkins, GISP Senior Project Manager

Gordon is a Senior Project Manager with 20 years of professional experience. Gordon is one of the leading expert consultants in Visualization and Visual Impact Assessment in the Northeast and is well known in the renewable energy industry. Gordon has extensive expertise in digital graphics and uses 2-D and 3-D software applications used to create visual simulations and effectively communicate design concepts.

As a Senior Project Manager with EDR, Gordon’s responsibilities include the ongoing evaluation and development of our technical methodologies used in visual impact assessment, including new techniques in data collection, processing and analysis, and 3-D modeling. Gordon is also responsible for assigning, scheduling and coordinating assistance from the in-house multi- disciplined team of professionals. He remains hands-on throughout the project, overseeing and advising the EDR Team as needed, as well as providing quality assurance.

education employment history Bachelor of Landscape Architecture, Ecology Emphasis, State University Senior Project Manager, Environmental Design & Research, Landscape of New York College of Environmental Science and Forestry, 2001. Architecture, Engineering & Environmental Services, D.P.C., Syracuse, NY, 2016-present. Associate of Arts, Keystone College, La Plume, PA, 1998. Project Scientist- Visualization and GIS Specialist, ESS Group, Inc., East registration / certifications Providence, RI, 2011-2016. Certified Geographic Information Systems Professional (GISP) Senior Visual Analyst- Project Manager, Saratoga Associates Landscape Architects, Architects, Engineers, and Planners, P.C., Syracuse, NY, 2008- Federal Aviation Association, Unmanned Aerial Vehicle (UAV) Pilot 2011. Certification for Commercial Flights Project Manager and Visualization Specialist, Environmental Design professional affiliations & Research, Syracuse, NY, 2001-2008. Member, Alliance for Clean Energy New York

Member, American Wind Energy Association project experience Sunrise Wind Farm Project, Visual Impact Assessment, Offshore MA/RI- Completed the visual assessment associated with state renewable energy development bid process and provided technical oversight of all visual impact studies including field photography and survey, visual simulation, and preparation of the visual assessment report. Revolution Wind Farm, Visual Impact Assessment, Offshore MA/RI- This project includes the on-going preparation of a visual impact assessment associated with an offshore wind farm located off the coasts of Massachusetts and Rhode Island. Senior project manager responsible for technical oversight of all visual impact studies including field photography and survey, visual simulation, and preparation of the visual assessment report. South Fork Wind Farm, Visual Impact Assessment, Offshore MA/RI- This project involved a visual impact assessment associated with an offshore wind farm located approximately 19 miles off the coast of Block Island Rhode Island. Served as senior project manager and provided technical oversight for field photography and survey, curvature of the earth calculations, viewshed methodology, simulations, and report production. Also provided graphic support for public outreach and education efforts.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

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Gordon Perkins, GISP Senior Project Manager

Skipjack Wind Farm, Visual Impact Assessment, Offshore DE- This project includes a full visual impact assessment associated with an offshore wind farm located off the coast of Delaware and Maryland. Provided project management and technical oversight for field photography and survey, curvature of the earth calculations, viewshed methodology, simulations, and report production. Also provided graphic support for public outreach and education efforts. Icebreaker Wind Project, Erie County, Cleveland, OH- This project included Visual Impact Assessment for a proposed 20 megawatt (MW) offshore wind project in Lake Erie. Obtained photographs, assisted with preparation of visual simulations, and oversaw production of Visual Impact Assessment Report. NYSERDA Offshore Wind Master Plan – Completed a Visibility Threshold Study for the New York State Offshore Wind Masterplan to determine the potential visual impact threshold for the placement of offshore wind energy area nominations. The study included an analysis of past weather data to predict prevailing conditions and visibility, visual simulations, and a compendium report. Galloo Island Wind Project, Jefferson County, NY- Prepared Visual Impact Assessment and technique support for proposed 30-turbine wind energy facility located on an island in Lake Ontario. Block Island Wind Farm, Block Island, RI- This project involved a proposed 30 MW wind farm facility located in the Atlantic Ocean, 3 miles off the coast of Block Island. Provided preliminary visual simulations and involved in on-going research associated with daytime and nighttime visibility thresholds of offshore turbines. Also involved in studies associated with the public acceptance of offshore wind farms. Long Island Offshore Wind Park (LIOWP), Long Island, NY- Prepared visual simulations of the Long Island Offshore Wind Park (LIOWP) Project, a proposed 140-megawatt offshore wind power project. Provided daytime simulations of the project from multiple locations on the southern Long Island shoreline. As a sub consultant to ENSR, EDR performed photographic and survey fieldwork and detailed computer modeling to develop realistic simulations of the proposed wind farm. EDR also participated in public outreach meetings and workshops concerning the project. Cape Wind Offshore Wind Farm, Nantucket Sound, MA- Created survey accurate visual simulations for America’s first offshore wind proposal. Completed daytime and, first in the industry nighttime visual simulations, depicting a 420-megawatt wind farm. Provided fieldwork oversight and photography from critical points throughout Cape Cod and the Islands. BOEM Offshore Visualizations for the MA/RI WEA- Prior to EDR, Created over 500 surveys accurate visual simulations depicting the BOEM wind energy areas in Massachusetts and Rhode Island. Used digital imaging techniques to depict four seasons and four times of day from each viewpoint. Contracted survey and meteorological experts to produce predictive visibility models. Tobacco Valley Solar Farm , Simsbury, CT- Completed an abbreviated visual assessment for a 26 megawatt solar facility and created a mitigation plan which included vegetative screening, project setbacks from residential properties, and alternative fencing materials. Also testified before the Connecticut Siting Council and participated in settlement negotiations with the Town of Simsbury. Canisteo Wind Farm , Steuben County, NY- Developed a Visual Impact Assessment (VIA) under Article 10 Regulations, for a 122-turbine project. The Visual Impact Assessment Report evaluated potential project visibility within the study area, identified key views, and assessed visual impacts associated with the proposed wind power project. Also completed a Visual Impact Assessment for the associated transmission line under Article VII regulations. Alle-Catt Wind Farm , Allegany, Cattaraugus, and Wyoming Counties, NY- Developed a Visual Impact Assessment (VIA) under Article 10 Regulations for a 117-turbine project. The Visual Impact Assessment Report evaluated potential project visibility within the study area, identified key views, and assessed visual impacts associated with the proposed wind power project. Hardscrabble Wind Power Project, Towns of Fairfield, Norway, & Little Falls in Herkimer County, NY- Developed viewshed maps and created visual simulations for the Visual Impact Assessment (VIA) for a 61-turbine project. Assisted with preparation of the Visual Impact Assessment Report which evaluated potential project visibility within the study area, identified key views, and assessed visual impacts associated with the proposed wind power project. Maple Ridge Wind Farm, Lewis County, NY- Assisted in the completion of a visual analysis for a 320-megawatt wind farm in upstate New York. Completed field verification (balloon study), visual simulations, viewshed analysis, and nighttime impact assessment. Jordanville Wind Power Project, Towns of Stark & Warren in Herkimer County, NY- Developed viewshed maps and created visual simulations for the Visual Impact Assessment (VIA) for a proposed 150 MW, 75-turbine project. The VIA report described visible components of the proposed project, defined the visual character of the study area, and inventoried and evaluated visual resources and viewer groups. The study also evaluated potential project visibility within the study area, identified key views, and assessed visual impacts associated with the proposed wind power project.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

GWP-PF1 Page 2 of 4

Gordon Perkins, GISP Senior Project Manager

Cohocton Wind Power Project, Town of Cohocton in Steuben County, NY- Prepared visual simulations for the Visual Impact Assessment (VIA) for an 82 MW, 41-turbine project. Assisted with preparation of the Visual Impact Assessment Report which evaluated potential project visibility within the study area, identified key views, and assessed visual impacts associated with the proposed wind power project. Marble River Wind Farm, Towns of Clinton & Ellenburg in Clinton County, NY- Created visual simulations for the Visual Impact Assessment (VIA) for a 200 MW, 109-turbine project. Assisted with preparation of the Visual Impact Assessment Report which evaluated potential project visibility within the study area, identified key views, and assessed visual impacts associated with the proposed wind power project. Dairy Hills Wind Farm, Towns of Castile, Covington, Perry, & Warsaw in Wyoming County, NY- Conducted visual field work and created visual simulations for a 160 MW, 80-turbine project. Assisted with preparation of the Visual Impact Assessment Report that described the appearance of visible components of the proposed project, defined the visual character of the study area, and inventoried and evaluated visual resources and viewer groups. The study also evaluated potential project visibility within the study area, identified key views, and assessed visual impacts associated with the proposed wind power project. Jamestown Board of Public Utilities Power Plant & Operations Center, Jamestown, NY- Prepared visual simulations for a 40 MW clean-coal power- generating plant and operations center. Visual impacts of the project were assessed by creating computer models of the proposed facilities and computer- assisted visual simulations of potential impacts as viewed from representative viewpoints. Assisted with preparation of Visual Impact Assessment Report that evaluated project visibility and visual impact on sensitive receptors and identified mitigation options, which included recommendations regarding design and siting, the color and texture of built materials, and lighting. Clear River Energy Center & Burrillville Interconnection Project, Burrillville, RI - Prepared a visual impact assessment for a proposed 900 MW natural gas generating plant and interconnection transmission line. Visual impacts of the project were assessed by creating computer models of the proposed facilities and computer-assisted visual simulations of potential impacts as viewed from representative viewpoints. Provided expert witness testimony before the Rhode Island Energy Facilities Siting Board. Southern Rhode Island Transmission Project, East Greenwich, RI- Completed photography and field verification for a 7.3-mile 115kV transmission line and associated substation. Created visual simulations representing realistic and accurate right-of-way clearing and proposed improvements. Provided expert witness testimony before the Rhode Island Energy Facilities Siting Board. Flat Rock Transmission Line, Lewis County, NY- Preformed viewshed mapping, line of sight cross sections and field verification for visual impact assessment of a 10-mile, 230 kV transmission line. Also prepared eight photo simulations of the proposed project. New York Regional Interconnect, New York State- Coordinated field operations for over 1000 visual resources over a 190Mile (570 Square Mile) Study area. Team leader in the selection and production of simulation for over 75 viewpoints. Provided expert witness testimony before the Public Service Commission of New York State. Empire Newsprint Recycling & Power Plant, Rensselaer County, NY- Created an architecturally detailed 3-D model and photo simulations of a proposed power plant (including cooling tower and stack plumes) and an associated 345 kV transmission line. Also assisted with fieldwork involving photo documentation of existing views. Simulations were part of a Visual Impact Assessment for the proposed project, prepared as part of the PSC Article VII application. New York State Statewide Wireless Network- Developed visual simulations for the Generic Visual Impact Assessment (GVIA) included as an appendix of the DEIS prepared for the siting of wireless communications towers throughout New York State. The report defined landscape similarity zones and viewer groups, identified sensitive resources/receptors, supervised the development of visual simulations, and participated in the preparation of the GVIA report. Tompkins County Public Safety Communications System, Tompkins County, NY- Developed viewshed maps and visual simulations for Visual Impact Assessment component of the Draft Environmental Impact Statement (DEIS) prepared for the siting of nine new towers for wireless communications. Bushkill Communications Tower, Town of Bushkill, PA- Conducted fieldwork and prepared viewshed maps and visual simulations to evaluate the visibility and visual impact of a proposed wireless communication facility. The focus of the evaluation was the project’s potential impact on the Delaware Water Gap National Recreation Area. Analytical results were used by the project developer in negotiations with National Park Service. Kaal Rock Connector, City of Poughkeepsie, NY- Prepared a Visual Assessment for three design alternatives associated with a multiuse trail connection on the Historic Hudson River. Completed simulations for the three concept designs and designed a rating system to determine the design with the greatest visual appeal. Completed an abbreviated visual assessment report to assist regulators in decision-making.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 3 www.edrdpc.com

GWP-PF1 Page 3 of 4

Gordon Perkins, GISP Senior Project Manager

Hudson River Proposed Anchorage Areas, NY- Prepared animated fly-through videos using drone footage and 3D overlays from Yonkers to Poughkeepsie, New York to demonstrate the visual effects of a proposal by the United States Coast Guard to create several new anchorage areas along the shores of the Hudson River. This fly-through animation was used in a media campaign to stop the permitting of the anchorage areas. Interstate 81 (I-81) Viaduct Project, Visual Impact Assessment, City of Syracuse, Onondaga County, NY- Prepared a Visual Impact Assessment that was conducted in accordance with Federal Highway Administration (FHWA) Visual Impact Assessment protocol as part of NEPA review as part of a consultant team with Parsons, AKRF, Inc., and TWMLA for the replacement of approximately 5 miles of elevated Interstate highways in the City of Syracuse, New York (NYSDOT PIN 3501.60, D031085). NYS Route 3 Community Development Study, Jefferson County, NY- Provided graphic and technical assistance in this highway corridor development guideline package prepared for the Tug Hill Commission. Assisted in creating a professional, full-length video and a 150 slide DVD presentation with 3-D animations and videography. University Avenue, Syracuse, NY- This project included recommendations and guidelines for street improvements along University Avenue, a main corridor onto the Syracuse University campus. Responsible for creating photo-renderings from conceptual plans that illustrated the proposed improvements to pedestrian and vehicular spaces. Hamlet of Brewerton Revitalization Project, Onondaga County, NY- Prior to EDR, This project included a multimillion-dollar highway and park design improvement project. Provided expertise in state design guidelines and federal grant guidelines. Presented at major televised public outreach events. Walden Pond Shoreline Erosion Assessment & Monitoring- Prior to EDR, Designed a system by which MASS DCR can photographically document erosion rates and severity. Produced an interactive map package which allows the user to compare multiple years of erosion data and photographs. Provided field survey and documentation to demonstrate to rate of erosion. Town of Dennis Comprehensive Dredge & Beach Nourishment Plan, Town of Dennis, MA- Prior to EDR, Completed dredge design and grading for the Bass River and associated mooring basins. Created permitting drawings for dredge and beach nourishment using LIDAR and bathymetry survey data. Assisted the Town of Dennis in a cost benefit analysis to prioritize dredging activity. Winchester Country Club Course Expansion, Winchester, MA- Prior to EDR, Provided the design, grading and permitting for a 15-acre golf course expansion. Provided expertise in invasive species management and wetland buffer enhancement. Performed cut fill calculations and watershed analysis.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 4 www.edrdpc.com

GWP-PF1 Page 4 of 4

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF

JOHN D. HECKLAU

ENVIRONMENTAL DESIGN & RESEARCH,

LANDSCAPE ARCHITECTURE, ENGINEERING &

ENVIRONMENTAL SERVICES, D.P.C.

Case No. 17-F-0655 HECKLAU

1 Q: Please state your name, employer, and business address.

2 A: John D. Hecklau, Environmental Design & Research, Landscape Architecture, Engineering &

3 Environmental Services, D.P.C. (EDR), 217 Montgomery Street, Suite 1000, Syracuse, New York

4 13202.

5 Q: What is your position at EDR?

6 A: I am a Principal in EDR’s Environmental Division.

7 Q: How long have you been employed with EDR?

8 A: I have been employed with EDR since 1989.

9 Q: Please describe your educational background and professional experience.

10 A: I received a Bachelor of Arts in Biology from Middlebury College in Middlebury, Vermont. I then went

11 on to receive a Master of Science in Environmental and Forest Biology, specializing in Wildlife

12 Biology, from the State University of New York, College of Environmental Science and Forestry in

13 Syracuse, New York. I am a Certified Wildlife Biologist, and worked for the Connecticut Department

14 of Environmental Protection (Wildlife Bureau) and the New York Power Authority (Environmental

15 Programs Division) before joining EDR in 1989. I have over 30 years of experience performing

16 and/or supervising projects involving wetlands delineations, environmental impact assessments,

17 vegetation and wildlife studies, visual impact assessments, natural resource management planning,

18 wetland permitting, and environmental compliance monitoring. Additional information on my

19 experience is presented in my resume, which is included as Exhibit ___ (JDH-PF1): Resume of John

20 D. Hecklau.

21 Q: Please describe your current responsibilities with EDR.

22 A: As a Principal within EDR’s Environmental Division, I oversee EDR’s environmental permitting,

23 impact assessment, and management projects. I am responsible for visual impact analysis, wetland

24 permitting, natural resource management planning, wildlife studies, environmental impact analysis,

Page 2 of 4 Case No. 17-F-0655 HECKLAU

1 and environmental compliance monitoring on behalf of EDR’s clients. I have extensive experience

2 reviewing the environmental impacts of wind, solar and other energy projects on a variety of

3 resources, including wetlands and streams, wildlife, threatened and endangered species, and

4 visual/aesthetic resources. Of particular relevance to my testimony in this matter, I have overseen

5 preparation of over 50 visual impact assessments for renewable energy projects.

6 Q: Have you previously testified before the New York State Public Service Commission or Board

7 on Electric Generation Siting and Environment (“Siting Board”)?

8 A: Yes, I have submitted testimony in Case No. 97-F-1563, Athens Generating; Case No. 98-F-1968,

9 Ramapo Energy Limited Partnership; Case No. 99-F-1191, Astoria Energy, LLC; Case No. 03-T-

10 0515, Flat Rock Wind Power; Case No. 10-T-0154, St. Lawrence Gas Company, Inc.; Case No. 13-

11 T-0469, Central Hudson & Gas Electric Corporation; Case No. 15-F-0122, Baron Wind Project; Case

12 17-F-0182, Mohawk Solar Project; Case 16-F-0546, Heritage Wind Project; Case No. 16-F-0205,

13 Canisteo Wind Project; Case No. 17-F-0282, Alle-Catt Wind Project; and Case No. 18-F-0087, Flint

14 Mine Solar Project.

15 Q: Have you previously served as an expert witness before any other court, agency, or other

16 body on the subject you plan to offer testimony on today?

17 A: Yes, I have testified before the Rhode Island Energy Facilities Siting Board (EFSB), the New

18 Hampshire Site Evaluation Committee (SEC), and the Perquimans and Chowan County Boards of

19 Commissioners (North Carolina) regarding the visual impact of proposed wind power and/or

20 transmission projects.

21 Q: What is the purpose and scope of your testimony in this proceeding?

22 A: To sponsor certain portions of the Riverhead Solar 2 Application and the Exhibits thereto.

23 Q: What portion(s) of the Application is your testimony sponsoring?

24 A: Exhibit 24, Visual Impacts, and related appendices.

Page 3 of 4 Case No. 17-F-0655 HECKLAU

1 Q: Were these Exhibits, Application sections, or studies prepared by you or under your direction

2 and supervision?

3 A: Yes.

4 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data or

5 documents produced by persons other than yourself/your company? If so, please cite these

6 sources.

7 A: See Exhibit 24 for references.

8 Q: Does this conclude your testimony?

9 A: Yes.

Page 4 of 4

John D. Hecklau, Principal Environmental Services

John is a certified Wildlife Biologist with over 30 years of environmental planning and consulting experience, the majority of which has been associated with energy projects. He has been directly involved in the environmental review and permitting of over 50 commercial wind power projects as well as and environmental impact assessments for solar generation facilities, conventional power plants, and transmission lines. His expertise covers all facets of utility permitting, including siting, environmental review and analysis, ecological surveys, wetland delineation and permitting, liaison with regulatory agencies, as well as environmental compliance during construction. Since 1993, John has served as principal-in-charge or project manager on all of the firm’s visual impact assessment projects. Along with managing these projects, his role has typically included analyzing the results of the visual impact assessment, and completing the necessary reports and permitting required by federal, state, and local agencies. John has provided expert witness testimony, made numerous presentations, and published articles on visual impact issues associated with utility-scale wind power projects. education employment history Master of Science in Environmental & Forest Biology, Specializing in Principal, Environmental Design & Research, Landscape Architecture, Wildlife Biology, State University of New York, College of Environmental Engineering & Environmental Services, D.P.C., Syracuse, NY 2008- Science and Forestry, 1982. present. Bachelor of Arts in Biology, Middlebury College, 1979. Project Manager/Senior Ecologist, Environmental Design & Research, Syracuse, NY, 1995-present. professional affiliations Ecologist, Environmental Design & Research, Syracuse, NY, 1989-1994. Member, The Wildlife Society. Self-Employed Environmental Consultant, John D. Hecklau, Clinton, NY, Certified Wildlife Biologist, The Wildlife Society. 1988. Planning Board Member/Chairman, Town of Kirkland, NY. Resource Manager, Environmental Programs Division, New York State Power Authority, Marcy, NY, 1984-1987. Member, American Wind Energy Association. Wildlife Biologist, Connecticut Department of Environmental Protection, registration / certifications Burlington, CT, 1983-1984. Wildlife Biologist – The Wildlife Society. Wildlife Consultant, Central Park Conservancy, New York, NY, 1982-1983. project experience Block Island Wind Farm, Block Island, RI- Directed preparation of Visual Impact Assessments (VIAs) for the proposed Block Island Wind Farm and associated on-shore transmission facilities. The wind farm is a 30 MW facility located in the Atlantic Ocean, 3 miles off the coast of Block Island. On-shore facilities include electrical lines, switchyards, and substations. The project involved the preparation of daytime and nighttime simulations of the offshore turbines from viewpoints on Block Island and the mainland. Simulations of the above-ground on-shore components of the project were also prepared, including landscaping and architectural façade treatments of the switchyards. VIAs also included an inventory of visually sensitive resources, viewshed analysis, cross section analysis, and evaluation of visual impact. In addition to the VIAs, managed preparation of various presentation graphics for public outreach purposes, including poster boards, animated simulations, an interactive web site, and an animated “fly-through” video of the wind farm. Icebreaker Wind Project, Erie County, Cleveland, OH- Oversaw federal permitting efforts for a proposed 20-megawatt (MW) demonstration wind project off-shore of Cleveland, Ohio in Lake Erie. Permitting efforts included preparation of an Application to the Ohio Power Siting Board, Section 404/Section 10 permitting with the U.S. Army Corps of Engineers, Section 401 Water Quality Certification from the Ohio EPA, and approval from the International Joint Commission. Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

JDH-PF1 Page 1 of 5

John D. Hecklau, Principal Environmental Services

Jericho Rise Wind Farm, Towns of Bellmont & Chateauguy, Franklin County, NY- Directed the State Environmental Quality Review Act (SEQRA) review for this 37-turbine, 78 MW project. Oversaw preparation of a Supplemental Environmental Impact Statement (EIS), a Final EIS, and multiple support studies including a Visual Impact Assessment (VIA), a Shadow Flicker Analysis, Cultural Resources Reports (Archaeology and Historic Resources), a Wetland Delineation Report, and a Rare Plant Survey. Also coordinated preparation of local Wind Energy Permit Application and wetland/stream permit applications submitted to the U.S. Army Corps of Engineers and the NYS Department of Environmental Conservation. South Fork Wind Farm, Visual Impact Assessment, Offshore MA/RI – Oversaw preparation of a comprehensive VIA for a proposed offshore wind farm located on the outer continental shelf off the coast of Block Island, Rhode Island. Reviewed results of all technical analyses summarized visual impact evaluation conducted by a professional panel of landscape architects and provided QA/QC on final report and associated graphics. Skipjack Wind Farm, Visual Impact Assessment, Offshore DE- Oversaw preparation of a comprehensive VIA for a proposed offshore wind farm located on the outer continental shelf off the coast of Delaware and Maryland. Reviewed results of all technical analyses, summarized visual impact evaluation conducted by a professional panel of landscape architects, and provided QA/QC on final report and associated graphics LIPA Offshore Wind Park, Long Island, NY- Directed the preliminary visual studies associated with a 150 MW offshore wind power project being proposed by the Long Island Power Authority (LIPA). Project included preparation of visual simulations from heavily used beaches and state parks on the South shore. Graphics were used for public information and outreach efforts. Cape Wind Offshore Wind Farm, Nantucket Sound, MA- Directed the production of visual simulations and other graphics/analysis for America’s first proposed offshore wind power facility. Prepared visual methodology write-up for the project, responded to agency questions and information requests, and described the methodology and results of EDR’s visual studies at a public/agency forum sponsored by the Massachusetts Technology Forum. The project’s visual impact was a sensitive issue, subject to intense scrutiny by various interest groups. Sodeman Road Substation, Saratoga County, NY- Directed the preparation of an Article VII Application for a new National Grid substation tying into an existing Article VII transmission line. Also prepared a VIA, wetland delineation, and alternatives analysis for the project. Coordinated preparation of noise study and Stormwater Pollution Prevention Plan (SWPPP), and provided expert witness testimony. Aquidneck Island Reliability Project, Newport, RI- Directed the preparation of a VIA for the proposed upgrade of approximately 4.4 miles of National Grid 69 kV transmission line to 115 kV. The VIA also addressed construction of a new substation and retirement/removal of five substations. Specific tasks included field verification of project visibility, definition of landscape similarity zones and viewer groups, identification of sensitive resources/receptors, development of viewshed maps, preparation of visual simulations, impact evaluation, and preparation of the VIA report. Wild Meadows & Groton Wind Farms, Danbury & Groton, NH- Directed the preparation of VIAs and Shadow Flicker Analyses for two commercial wind power projects in New Hampshire. VIAs included viewshed analysis, photo documentation and visual simulations. Also assisted with public outreach efforts and state Site Evaluation Committee proceedings, including preparation of pre-filed testimony, response to discovery requests, and participation in a technical session and adjudicatory hearings as an expert witness. Eastover Road New 230/115kV Station & Transmission Line Loops, Rensselaer County, NY- Directed all environmental and civil engineering support to National Grid in their development of the proposed Eastover Road Substation and Tap Lines. Services provided on this project included preparation of a VIA, on-site wetland delineation and permitting, SEQRA documentation, Part 102 report preparation, site grading, and stormwater design, wetland mitigation area design and documentation, preparation of Stormwater Pollution Prevention Plan (SWPPP), and SWPPP inspections during construction. Environmental Compliance Monitoring during Wind Farm Construction, NY & MA- Directed environmental compliance monitoring during construction of four different wind farms for three different developers in New York and Massachusetts (Hardscrabble, Hoosac, Arkwright Summit and Copenhagen). Assisted with preparation of the Environmental Compliance Manuals and provided compliance training to project contractors. Oversaw and assisted EDR field staff with daily on-site monitoring, weekly Stormwater Pollution Prevention Plan (SWPPP) inspections, preparing reports, coordinating resolution of compliance issues with Construction Site Manager and contractors, and assuring compliance with local, state, and federal permit conditions. Deerfield Wind Power Project, Towns of Searsburg & Readsboro, Bennington County, VT- Directed the preparation of a National Environmental Policy Act (NEPA) compliant EIS for the first wind power project proposed on U.S. Department of Agricultural (USDA) Forest Service land. The project involves the proposed construction of 17 2.0 MW wind turbines on forested ridges in the Green Mountain National Forest. Project activities included preparation of a Public Information Plan, significant public outreach, project scoping, coordination with Forest Service staff, and review of subconsultant resource reports for inclusion in the EIS. A draft supplemental draft, and final EIS were prepared for the project. Responses to over 500 public comments on the draft EIS and 1,000 comments on the supplemental draft were prepared. Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

JDH-PF1 Page 2 of 5

John D. Hecklau, Principal Environmental Services

New England East-West Solution Project, MA, RI, CT- Directed preparation of VIAs for multiple National Grid transmission system improvement projects in Rhode Island and Massachusetts. The transmission system improvements involve upgrade of existing transmission lines, construction of new transmission lines, construction of new substations, and existing substation upgrades. Prepared VIAs for each project that included the identification of existing visually sensitive resources, photo documentation of existing views, and description of existing landscape character along over 75 miles of proposed transmission line route. Viewshed analyses of existing and proposed facilities were conducted, and over 20 visual simulations were prepared and rated by a professional panel of landscape architects. VIA reports were included in applications submitted to the State Utility Siting Boards. Also prepared pre-filed visual testimony, responded to discover requests, and provided testimony before the Rhode Island Energy Facility Siting Board. Southern Rhode Island Transmission Project, RI- Directed the preparation of the VIA and Supplemental VIA prepared for the proposed upgrade and extension of approximately 26 miles of an existing National Grid 115 kV transmission line in southern Rhode Island. The effort consisted of fieldwork, definition of landscape similarity zones and viewer groups, identification of sensitive resources/receptors, development of viewshed maps and visual simulations, impact evaluation, and preparation of the VIA report. Also provided expert witness testimony to the Rhode Island Energy Facility Siting Board. Maple Ridge Wind Power Project, Lewis County, NY- Directed SEQRA compliance, including preparation of Draft and Final EISs for the largest commercial wind power project in the Northeast. Oversaw production of all support studies and directly prepared ecological, wetlands, agricultural, and visual studies for 300 MW wind power project on the Tug Hill Plateau. Incorporate study results into the Draft EIS and responded to all public and agency comment in the Final EIS. Also assisted with state and federal wetland permitting on the project. Maple Ridge 230 kV Transmission Line Project, Lewis County, NY- Directed the preparation of Article VII Application to New York State Public Service Commission for a 10.3-mile-long 230 kV transmission line corridor. Conducted ecological, wetland, and visual fieldwork, prepared Visual Impact Assessment report, and provided expert witness testimony on ecological and visual issues. Reliant Energy Astoria Repowering Project, Queens County, NY- Directed VIA for proposed repowering of the existing Astoria Generating Project. The study involved identification of landscape similarity zones and viewer groups, viewshed mapping, cross sections, and visual simulations. Assisted with development of visual impact mitigation options, and provided expert witness testimony. TransEnergie Cross-Sound Cable Project, New Haven, CT & Shoreham, NY- Directed the study and prepared VIA report assessing visual impacts of submarine cable crossing of Long Island Sound. VIA focused on the visual impact of above-ground transition stations and associated structures. Neptune Regional Transmission System Project, Sayreville, NJ to Nassau County, Long Island, NY- Directed the study and prepared VIA report assessing visual impacts of above-ground components of submarine/underground transmission line in New York City metropolitan area. VIA focused on the visual impact of transition stations in Manhattan and on Long Island. Ramapo Energy Project, Rockland County, NY- Directed the preparation of comprehensive visual impact analysis for a proposed 1,100 MW gas-fired power plant proposed by American National Power. Study involved background data collection, viewshed mapping, line-of-sight cross sections, field evaluation, visual simulations, evaluation of visual impacts using the U.S. Army Corps of Engineers methodology, and exploration of various visual mitigation measures. Wrote the VIA report and assisted with preparation of the visual section of the Article X Application and provided expert witness testimony. Also assisted with ecological investigations, and preparation of Application text and testimony dealing with wildlife issues. Athens Power Project, Village of Athens, NY- Evaluated visual resources and visual impacts associated with construction of a 1,080 MW power plant proposed by PG&E National Energy Group. Also delineated state and federal wetlands and documented ecological conditions on the project site and along proposed off-site utility (gas, water, and electric transmission) corridors associated with the project. Assisted with field data collection, agency liaison, and preparation of a wetland delineation report and functional analysis. Oversaw preparation of the VIA as well as the Ecological Resources and Visual Resources sections of the Article X Application, and provided expert witness testimony on potential ecological impacts. Project was the first permitted under New York’s Article X power plant siting regulations. A & C Lines Rebuild Project, Central Hudson Gas & Electric Corporation, Dutchess County, NY- Directed preparation of an Article VII application, and associated support studies, for the rebuild of 11 miles of 115 kV transmission lines. Along with the preparation of the application, participated in settlement negotiations with state agencies, and oversaw production of the Environmental Management & Construction Plan (EM&CP). Will also be overseeing environmental compliance monitoring during project construction. Article VII Compliance Monitoring- Directed environmental compliance monitoring on three Article VII projects in Upstate New York. Projects included a 48-mile long natural gas pipeline (St. Lawrence Gas Norfolk to Chateauguay Transmission Line), an 11-mile long 115 kV transmission line (Central Hudson

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 3 www.edrdpc.com

JDH-PF1 Page 3 of 5

John D. Hecklau, Principal Environmental Services

A and C Line Rebuild Project) and a new substation tying into an existing Article VII line (National Grid Five Mile Road Substation). Directed efforts of on- site Environmental Monitors to assure compliance with all conditions of the project Environmental Management and Construction Plan (EM&CPs) and Stormwater Pollution Prevention Plans (SWPPPs). Assisted with environmental training of contractors, agency liaison, and reporting. Worked with agency staff and project sponsors to assure compliance with all environmental protection requirements during project construction, including protection of wetlands and streams, active agricultural land, threatened and endangered species, and archeological resources. Black Creek Park, Monroe County Parks, Towns of Chili & Riga, NY- Directed the development of a master plan for a largely undeveloped 1,500-acre County park, one third of which is made up of wetlands. Responsible for comprehensive study of ecological resources including field inventory of all wildlife, wetlands, and natural communities within the park, and an evaluation of the ecological significance/sensitivity of various areas. Oversaw wetland delineation and state and federal wetland permitting. Mendon Ponds Park, Monroe County Parks, Town of Mendon, NY- Directed ecological study of this 1,500-acre County park. The park is a designated National Natural Landmark, well known for its variety of rare species and unique natural communities, including fens, bogs, oak openings, and prairie remnants. Study involved species inventory, analysis of ecological value of various areas of the park, and management recommendations for the protection and enhancement of the park's ecological resources. Albany Pine Bush Preserve, Albany County, NY- Developed and updated a comprehensive management plan for a unique inland pine-barrens community. Project involved extensive data collection, public participation, and close coordination with members of the Albany Pine Bush Preserve Commission. Plan included resource inventory, management recommendations, an implementation plan, and an EIS that addressed the potential impacts of plan implementation, including land acquisition, fire management, and increased public use. publications / presentations

Presenter, Herkimer-Oneida Counties Comprehensive Planning Program / Land Use Training Conference, Marcellus Shale: Local Municipal Options, October 2011. Presenter, Land Use Planning Workshop, The Benefits of Sustainable Community Planning & Design, Jefferson Community College Center for Community Studies, April 2011. Hecklau, J. 2010. Technical Considerations in the Preparation of Visual Simulations of Off-Shore Wind Power Projects. Presentation at the American Wind Energy Association North American Off-Shore Wind Conference & Exhibition. October 5-7, 2010, Atlantic City NJ. Hecklau, J. and J. Gagliano. Local Review of Commercial Wind Power Projects. Presentation at Onondaga County Planning Federation Conference. January 21, 2009, Syracuse, NY. Hecklau, J. and M. Scipioni. Measuring Success of Wetland Mitigation & Monitoring. Presentation at Sustainable Solutions. June 12, 2008, Rochester, NY. American Society of Landscape Architects, New York Upstate Chapter Annual Conference. Hecklau, J. and B. Brazell. State and Environmental Quality Review Act & Public Participation. Presentation at Wind Energy Conference. April 5, 2008, Herkimer County Community College. Sponsored by Herkimer-Oneida Counties Comprehensive Planning Program. Hecklau, J. 2006. Evaluating the Visual Impacts of Wind Power Projects. North American Wind Power. 3 (June): 48-52. Hecklau, J. Visual Characteristics of Wind Turbines. Presentation at Technical Considerations in Siting Wind Developments Research Meeting. December 1-2, 2005, Washington, DC. Sponsored by the National Wind Coordinating Committee. Hecklau, J. Evaluating Visual/Aesthetic Impacts of Wind Power Projects. Presentation at the Second Wind Power Project Siting Workshop, Siting Wind Power Projects in the Eastern U.S. March 8-9, 2005 Boston, MA. Sponsored by the American Wind Energy Association (AWEA). Lamanna, B. and J. Hecklau. 2002. The Windmills of Madison County. New York State Conservationist. 56(5): 8-11. Hecklau, J. Overview of Wind Permitting Frameworks in Different Settings. Case Study 1: Madison, NY. Presentation at New England Wind Power Siting Workshop, October 24, 2001, Boston, MA. Sponsored by the National Wind Coordinating Committee. Hecklau, J.D., C. Palmero, E.T. Liverman and J. deWall Malefyt. 1987. Reducing the environmental impacts of stream crossings on a 345kV transmission line in New York. In W.R. Byrnes and H.A. Holt, eds. Fourth Symp. on Environmental Concerns in Rights-of-Way Manage. Purdue Univ., West Lafayette, IN. Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 4 www.edrdpc.com

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John D. Hecklau, Principal Environmental Services

Liverman, E.T., J.D. Hecklau and C. Palmero. 1987. Minimization of soil erosion and siltation during construction of the Marcy-South 345kV transmission facilities. pp. 241-253. In Erosion Control: You're Gambling Without It. Proc. of Conf. XVII. International Erosion Control Assoc., Pinole, CA. 335 pp.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 5 www.edrdpc.com

JDH-PF1 Page 5 of 5 NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF

JANE E. RICE

DIRECTOR OF PLANNING

ENVIRONMENTAL DESIGN & RESEARCH

LANDSCAPE ARCHITECTURE, ENGINEERING &

ENVIRONMENTAL SERVICES, D.P.C.

Case No. 17-F-0655 RICE

1 Q: Please state your name, employer, and business address.

2 A: Jane E. Rice, Environmental Design & Research, Landscape Architecture, Engineering &

3 Environmental Services, D.P.C. (EDR), 217 Montgomery Street, Suite 1000, Syracuse, New York

4 13202.

5 Q: What is your position at EDR?

6 A: I am a Principal at EDR and Director of Planning.

7 Q: How long have you been employed with EDR?

8 A: I have been employed at EDR since August 2005.

9 Q: Please describe your educational background and professional experience.

10 A: I received a Bachelor of Arts Degree from Creighton University in Omaha, Nebraska, in 1981 and a

11 Juris Doctor from Creighton Law School in 1986. I practiced law with several private law firms until

12 1991 when I joined the master program at the State University of New York College of Environmental

13 Science and Forestry. I obtained a Masters in Landscape Architecture in 1995. I was employed by

14 Clough Harbor and Associates until 2005 when I joined EDR. Since 1995, I have worked in the

15 capacity as Planner, Project Manager, Senior Project Manager, and Director of the Planning practice.

16 I have over 20 years of experience in community and land use planning, with 10 years of experience

17 preparing and/or supervising projects involving socioeconomic reports for wind energy projects. A

18 copy of my resume is submitted as Exhibit ____ (JER-PF1): Resume of Jane E. Rice.

19 Q: Please describe your current responsibilities with EDR.

20 A: As Principal and Director of Planning, I oversee EDR’s planning practice, which consists of various

21 community-centered planning initiatives that include comprehensive plans, waterfront revitalization

22 planning and design, brownfield redevelopment planning, developing downtown and neighborhood

Page 2 of 4

Case No. 17-F-0655 RICE

1 revitalization strategies, zoning and land use regulations, and agriculture and farmland protection

2 plans. A portion of our planning work includes coordinating or conducting socioeconomic analyses.

3 Q: Have you previously testified before the New York State Public Service Commission or Board

4 on Electric Generation Siting and the Environment (“Siting Board”)?

5 A: Yes. I submitted written testimony to the Siting Board in the proceedings related to the Cassadaga

6 Wind Project (Case No. 14-F-0490), Baron Wind Project (Case No. 15-F-0122) and Bluestone Wind

7 Energy Facility (Case No. 16-F-0559) and testified orally in conjunction with the Cassadaga Wind

8 Project. In addition, I have submitted pre-filed testimony in the proceedings related to the Galloo

9 Island Wind Energy Facility (Case No. 15-F-0327), High Bridge Wind Project (Case No. 18-F-0262),

10 the Heritage Wind Project (Case No. 16-F-0546), and the Flint Mine Solar Project (Case No. 18-f-

11 0087).

12 Q: Have you previously served as an expert witness before any other court, agency, or other

13 body on the subject you plan to offer testimony on today?

14 A: No.

15 Q: What is the purpose and scope of your testimony in this proceeding?

16 A: To sponsor certain portions of the Riverhead Solar 2 Application and the Exhibits thereto.

17 Q: What portion(s) of the Application is your testimony sponsoring?

18 A: Exhibit 4, Land Use and Exhibit 27, Socioeconomic Effects.

19 Q: Were these Exhibits, Application sections, or studies prepared by you or under your direction

20 and supervision.

21 A: Yes.

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Case No. 17-F-0655 RICE

1 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data or

2 documents produced by persons other than yourself/your company? If so, please cite these

3 sources.

4 A: See Exhibits for any references.

5 Q: Does this conclude your testimony?

6 A: Yes.

Page 4 of 4

Jane E. Rice, JD, Principal Director of Planning

Jane is a Principal and Director of Planning services at EDR. She is also a certified planner and licensed attorney with more than 25 years of professional experience in project management, community and land use planning, smart growth management and analysis, zoning, community engagement and outreach, economic development, and redevelopment / revitalization planning. She leads an in-house team of planning professionals who coordinate with in-house cultural resources management and historic preservation specialists, graphic artists, geographic information systems analysts, regulatory compliance specialists, and landscape architects to develop comprehensive planning initiatives. Jane earned a Master of Landscape Architecture degree from the State University College of Environmental Science & Forestry, a Juris Doctor from Albany Law School, and a Bachelor of Arts in Political Science degree from Creighton University. Jane is also a sought- after lecturer in topics related to Sustainable Land Use Planning & Design, Environmental Integrity, Form-Based Zoning Code, Community Character, and Community Engagement. She is currently a member of the American Planning Association (APA), New York State Chapter of the APA Board of Directors, New York Planning Federation, and New York State Bar Association; and has also served as Chair of the Village of Fayetteville Planning Board for more than two decades. education registration / certifications

Master of Landscape Architecture, State University of New York College of American Planning Association member (APA) Environmental Sciences and Forestry, Syracuse, NY, 1996. Juris Doctor Juris Doctor, Creighton University School of Law, Omaha, NE, 1982-1983, employment history Albany Law School, Albany, NY, 1984-1985. Principal, Director of Planning, Senior Planner, Environmental Design & Bachelor of Arts in Political Science, Creighton University, Omaha, NE, Research, Landscape Architecture and Engineering and Environmental 1981. Resources, D.P.C, Syracuse, NY, 2014-present. professional affiliations Senior Planner, Environmental Design & Research, Landscape Architecture and Engineering and Environmental Resources, D.P.C, Vice President, Onondaga County Planning Federation Board Syracuse & Rochester, New York, 2005-2014. Chairperson, Village of Fayetteville Planning Board Land Use Planner, Independent Consultant, Fayetteville, NY, 2004- 2005. Member, American Planning Association Land Use Planner, Clough Harbour & Associates LLP, Syracuse, NY, Member, Board of Directors, New York State APA – CNY Section 1997-2004. Attorney at Law, Independent Consultant, Fayetteville, NY, 1991-1994.

Attorney at Law, Scolaro Law Firm, Syracuse, NY, 1987-1991.

renewable energy project experience

Renewable Energy Permitting in Ohio- Supervised the preparation of socioeconomic reports for applications to the Ohio Power Siting Board (OPSB) for commercial scale wind and solar power projects. In accordance with the Ohio Administrative Code, the certification applications addressed potential project- related impacts to ecological resources, soils and geology, groundwater, air quality, aesthetics, agricultural land use, cultural resources, and socioeconomics. All applications have been accepted as complete after initial submittal. Projects include:

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

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Jane E. Rice, JD, Principal Director of Planning

Republic Wind Farm, Seneca and Sandusky Counties, OH - Oversaw the preparation of socioeconomic analysis and subsequent report for the Certificate Application to the OPSB for a proposed 20 megawatt (MW) offshore wind project.

Emerson Creek Wind Farm and Transmission Line, Erie and Huron Counties, OH - Conducted socioeconomic analysis and prepared the subsequent report for the Certificate Application to the OPSB.

Timber Road IV Wind Farm and Transmission Line, Paulding County, OH – Oversaw the preparation of socioeconomic analysis and subsequent report for the Certificate Application to the OPSB. Hillcrest Solar Project, Brown County, OH - Oversaw the preparation of socioeconomic analysis and subsequent report for the Certificate Application to the OPSB. Project Icebreaker, Erie County, Cleveland, OH - Oversaw the preparation of socioeconomic analysis and subsequent report for the Certificate Application to the OPSB.

Renewable Energy Permitting in New York – Supervised and contributed to the preparation of sections of applications submitted under Article 10 of the New York Public Service Law analyzing the socioeconomic and land use impacts of large-scale renewable energy projects, and conducted public information meetings, including the first such application submitted statewide. Projects include:

Copenhagen Wind Farm - Lewis County, NY – Oversaw the preparation of Socioeconomic section in the Environmental Impact Statement (EIS). Project is currently under construction, and was reviewed and approved through preparation of EISs in accordance with the State Environmental Quality Review Act (SEQRA), while also receiving approval from the New York State Department of Environmental Conservation (NYSDEC) under Article 15 and 24 of the Environmental Conservation Law (ECL). Allegany Wind Power Project - Cattaraugus County, NY - Oversaw the preparation of a standalone Socioeconomic Report as an appendix to the EIS. Project was reviewed and approved in accordance with the State Environmental Quality Review Act (SEQRA), and fully aligned with all necessary permits. Icebreaker Offshore Wind Farm - Cuyahoga County, OH - Oversaw the preparation of full standalone Socioeconomic Report as a component of the Application for Certificates of Environmental Compatibility and Public Need (Certificate Application.) Project is currently in the process of review from the Ohio Public Service Board. Scioto Ridge Wind Farm - Hardin and Logan Counties, OH - Oversaw the preparation of full standalone Socioeconomic Report as a component of the Application for Certificates of Environmental Compatibility and Public Need (Certificate Application). Crown City Wind Energy Project - Cortland County, NY - Oversaw the preparation of a standalone Socioeconomic Report as an appendix to the EIS. Project was reviewed in accordance with the State Environmental Quality Review Act (SEQRA).

other project experience

Lakeshore Enhancement Project, Onondaga Lake, Town of Geddes, Onondaga County, NY- Directed team that created site plans and designs, and conducted extensive community outreach and engagement activities, for adaptive reuse and ecological restoration of the 4,000 acres of the former Allied Corporation property (now owned by Honeywell Corporation). The purpose of this project is to remediate and reuse the Super Fund site in a more environmentally sensitive manner. Transit Study Phase 1 (SMART 1) on behalf of the CNY Regional Transportation Authority, Syracuse Metropolitan Transportation Authority, Syracuse, NY- Directed team providing community planning services, that include outreach and engagement activities to a team of national consultant to advance recommendations identified in the Syracuse Transit Analysis to pursue a higher-intensity transit services along the Destiny/Regional Transportation Center to Syracuse University and James Street/South Avenue corridors. Local Waterfront Revitalization Program (LWRP), NYSDOS, Town & Village of Clayton Jefferson County, NY- Directed team that developed the LWRP, conducted extensive community outreach and engagement activities, evaluated site and designed segments of the new RiverWalk waterfront connection and access to the St. Lawrence River. The Riverwalk, (Phase 2- NYSDOS / Phase 3- NYSDOT / LAFA Region 3), NYSDOT, Village of Clayton, Jefferson County, NY- Directed site planning and design services, that include community outreach and engagement activities in support of Phase 2 of the Riverwalk Project. Currently responsible for coordinating design of best options to support Phase 3 implementation.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

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Jane E. Rice, JD, Principal Director of Planning

Hiawatha Boulevard-Lodi Street Brownfield Opportunity Area Program (BOA), NYSDOS, City of Syracuse, NY- Directed team (with Sasaki Associates) that developed a Nomination Study that incorporates a 136-acre area with 11 potential brownfield properties. This is a main artery to a vital, heavily traveled section of Syracuse. It is also an area that is suffering from depressed commercial properties and deteriorating housing stock, both of which are intermixed with active businesses. Managed team that developed the BOA, conducted extensive community outreach and engagement activities, evaluated site and designed visionary outcomes for this a low-income neighborhood. Hiawatha Boulevard-Lodi Street Brownfield Opportunity Area Program, City of Syracuse, NY- Directed the team that served as the Lead Consultant in association with Sasaki Associates to create a Nomination Study for the Hiawatha Boulevard/Lodi Street Brownfield Opportunity Area within the City of Syracuse. This BOA incorporates a 136-acre area with approximately 11 potential brownfield properties. The area is a main artery to a vital, heavily traveled section of Syracuse. It is also an area that is suffering from depressed commercial properties and deteriorating housing stock, both of which are intermixed with active businesses. This BOA presents strategic opportunities to stimulate economic development and community revitalization. It is in close proximity to the Carousel Center, a regional retail mall which has recently expanded, and that attracts millions of visitors each year, providing a critical mass of people and vehicles passing through the Hiawatha Boulevard corridor. The project area also serves as a major transportation route to access the Alliance Bank Stadium, the home field of the Chiefs, which averages half a million ticket sales per year. It is also situated adjacent to the Central New York Regional Market, which houses hundreds of stands and attracts more than a million visitors annually, as well as the Regional Transportation Center. As a result, this BOA provides a significant opportunity for the successful redevelopment of vacant, underutilized and blighted properties located in an area with very high visibility. (2011-2013) Local Waterfront Revitalization Program (LWRP), NYSDOS, City of Ogdensburg, St. Lawrence County, NY- Directed team that developed an amendment to the LWRP, conducted extensive community outreach and engagement activities, designed conceptual land use patterns, and assisted the City in identifying policies and procedures that will implement the LWRP through a series of priority projects for improving waterfront connections and economic development opportunities. Local Waterfront Revitalization Program (LWRP), NYSDOS, Town of Alexandra & Village of Alexandria Bay, Jefferson County, NY- Directed team that identified and designed visionary outcomes for revitalization of the St. Lawrence River waterfront. Assisted in identifying opportunities for waterfront use and development, and to adopt appropriate policies and implementation strategies. Ongoing development projects include improvement to the existing Scenic View Park and creation of a new river walk along the River. Conducted extensive community outreach and engagement activities. I-81 Viaduct- Step 2 Scoping & Preliminary Design Project, NYSDOT, City of Syracuse, NY- Coordinated extensive community outreach and engagement activities as a member of the Parsons Team to determine design of best options for redevelopment of this major transportation hub project located close to Downtown and University Hill area. Local Waterfront Revitalization Program (LWRP), NYSDOS, Village of Sackets Harbor, Jefferson County, NY- Directed team that developed the LWRP, conducted extensive community outreach and engagement activities, evaluated site and designed visionary outcomes. This effort included analyzing opportunities and constraints in the Village, establishing a framework of policies to protect and enhance the resources of the Village and connections to the St. Lawrence River, and by developing proposals to capitalize on the opportunities of the waterfront within the context of established policies. East Main Street Marketing District Plan, Rochester, NY (LAFA Region 4), NYSDOT, City of Rochester, NY- Directed site planning services, that include community outreach and engagement services, to a team of national and local consultants to identify multi-modal circulation, access and parking improvements along with recommendations for land use development, streetscape enhancements, and community branding, as well as strategies to promote housing opportunities in the area. Niagara Gorge RIM Ecological Restoration Plan (Robert Moses Parkway Removal Study), City of Niagara Falls, NY- Directed team that quantified economic, environmental, and social costs and benefits of roadway removal and natural resource restoration proposal, and that analyzed various potential impacts including traffic distribution, active transportation, buffering, naturalization, environmental quality, and local economic development opportunities. American Society of Landscape Architects Merit Award for Planning Agricultural Enhancement Plans, Tioga, Broome and Ontario County, NY- Directed public participation and outreach activities, researching countywide agricultural land uses, and agricultural economic concerns, advising county on analysis of priority lands to be protected, and drafting recommendations to drive sustainable growth consistent with industry and environmental best practices, and NYSDAM guidelines. Niagara Falls Robert Moses Parkway Removal- Step 2 Scoping & Preliminary Design Project, NYSDOT/NYSOPRHP, Niagara Falls, NY- Directed extensive community outreach and engagement activities, and landscape design to determine and depict best options, for redevelopment of the northern section of this major transportation corridor project. Robert Moses Parkway North Segment Step 2 Scoping & Preliminary Design Project, Niagara Falls, NY- Directed the restoration of the Niagara Gorge Rim along the upper Niagara River will be transformative for the City of Niagara Falls. A one-mile stretch of the 50-year old, four-lane Robert Moses Parkway from Main Street in the City of Niagara Falls to its intersection with Findlay Drive will be removed to allow for a re-greening of the park with multi-use trails, improved scenic overlooks, and other park amenities. Whirlpool Street will be improved as a complete street reconnecting the neighborhoods to the park. As one of the subconsultants on the consulting team EDR worked on developing three alternative concepts from which the preferred concept was selected, Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 3 www.edrdpc.com

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Jane E. Rice, JD, Principal Director of Planning

as well as simulations to illustrate the proposed gateways, streetscape improvements, and other scenic overlooks. We participated in community outreach, engaging the community throughout the process, and provided an assessment of potential impacts on ecological resources, including threatened and endangered species. Girl Scouts Feasibility Study & Master Plan, Tomkins County, Ithaca, NY- Directed a campus and facilities master plan as developed for all 65 acres of Camp Comstock. This master planning process included, site visits, stakeholder meetings, research on local development regulations, and historic and cultural resources relevant to the camp. The effort included improvements to existing facilities as well as new facilities and uses intended to generate new and sustainable revenues for the Girl Scouts. While developing the master plan we continuously discussed operational and programming issues / needs / preferences so that all aspects are aligned with the recommendations for future improvements and new development. The final Master Plan Report includes the initial feasibility study for all four Girl Scout Camps, the recommendation to initially invest in Camp Comstock for facility improvements as well program development, and the Master Plan with planning and design details on connectivity throughout the main camp, facility improvements, new development and minor but critically important amenities. Plan for Reconnecting the Erie Canal Gateway, Town of DeWitt, Onondaga County, NY- Directed the EDR team that was collaborating with the town of DeWitt to prepare a plan for the revitalization of the waterfront along the NYS Canal System. The plan is proposed to include: visioning for the historic canal corridor, assessment of development patterns, identification of land and water use controls, and development of revitalization policies and implementation strategies. Work will include planning for a segment of the canal way trail that would close the gap between the Town of Dewitt and the Town of Camillus. Agricultural & Farmland Protection Plan, Ontario County, NY- Directed the EDR team that was collaborating with Ontario County in the development of their Enhancement Plan. EDR is designing and facilitating a community outreach plan with the goal of engaging local farmers, agricultural producers, and stakeholders in the local agricultural business, and facilitated several focus group meetings. With the community’s direct input, and through targeted analysis, we will make recommendations that touch upon local land use regulations, regional policies in support of agricultural producers and businesses, marketing, economic development, and implementation procedures for the Agricultural Enhancement Plan. Agricultural & Farmland Protection Plan, Tioga County, NY- Directed the EDR team that collaborated with Tioga County in the development of their Agriculture and Farmland Protection Plan. We designed and facilitated a community outreach plan with the goal of engaging local farmers, agricultural producers, and stakeholders in the local agricultural business. EDR developed, facilitated, and analyzed a SWOT (Strengths, Weaknesses, Opportunities, and Threats) exercise with farmers throughout the county, focusing on alternative energy opportunities, commerce and marketing, and public policy. With the community’s direct input, and through targeted analysis, our findings and recommendations touched upon local land use regulations, regional policies in support of agricultural producers and businesses, marketing, economic development, and implementation procedures for the Agricultural and Farmland Protection Plan. Skunk City Neighborhood Master Plan, Syracuse, NY- Directed the EDR team that worked in collaboration with staff from the Department of Neighborhood and Business Development and neighborhood advocates, which drafted the Skunk City Neighborhood Master Plan for the City of Syracuse in 2012. Located on the city’s west side, between Strathmore, Tipp Hill, and the Near Westside, Skunk City is a neighborhood where relatively modest public investments could have an outsized impact on residents’ quality of life. Our work within the neighborhood sought to increase neighborhood safety, stabilize property values, encourage new investment, reutilize abandoned properties, and improve pedestrian connectivity within and around the neighborhood. The principal intent of the Skunk City Neighborhood Master Plan is to make strategic and incremental improvements where such actions could have a positive influence on the environmental, economic, and social fabric of the community. Sackets Harbor Zoning, Sackets Harbor, Jefferson County, NY- Directed the EDR team that was retained along with Joel Russell, Esq. to assist the Village of Sackets Harbor in rewriting their zoning regulations to foster the village’s growth with a sensitivity towards its cultural resources and its traditional village core and rural edge. EDR completed a community buildout visualization to assist villagers envision its future growth under the then-existing zoning regulations. The potential loss of natural and cultural resources prompted the village to undertake the development of a new hybrid zoning code that applies a form-based structure. The new zoning law provides development regulations that address site layout, architectural treatments, and landscape standards that preserve the natural resources within the community. The new zoning law utilizes graphics and tables to provide clarity and improve readability. Carrier Dome Rainwater Harvesting, Syracuse, NY- Directed the EDR team that designed and developed interpretive materials. In the spirit of the Onondaga County Save the Rain program and with the goal of increasing its sustainable practices, Syracuse University embraced the concept of capturing and using the rainwater that falls on the roof of the Carrier Dome. With the Rainwater Harvesting System enough water is captured to flush half the Dome’s toilets and urinals during major Dome events. The Rain Water Harvesting System consists of two exterior 25,000-gallon storage tanks, and two interior 4,500 gallon tanks that will hold rainwater captured from approximately one third of the Carrier Dome’s roof. Teamed with a local engineering firm, and two Syracuse University graphic design students, EDR facilitated several design workshops with students and faculty to design, select, and develop a logo for the Carrier Dome Rain Harvesting System as well as wall murals and a 3D model/video. EDR facilitated the design of interior interpretive wall murals, exterior signage, and an interpretive video about the rainwater harvesting process as well benefits derived from using such a system. Oswego Brownfield Opportunity Area Program, Oswego County, NY- Directed the team that provided planning and design services to identify what is needed to achieve a coherent and integrated urban development program that preserves and protects the best of what exists and incorporates new

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Jane E. Rice, JD, Principal Director of Planning

development in a compatible manner. The design will build on existing infrastructure, incorporate existing historic fabric where appropriate, and identify appropriate patterns and forms for new development. EDR has also been charged with identifying what is necessary to create a memorable place through development of an urban design concept that incorporates a clear organization of sites, streets and open space. (2010-2012) Finger Lakes Sustainability Plan- Directed the team charged with development of indicators of sustainability in the agricultural and forestry sectors of a 9- county region in Western New York. Facilitated outreach initiatives and analyzed strategies and targets for sustainable development. Comprehensive Plan Update, Town of Canandaigua, NY- Directed the team that researched existing conditions, and analyzed economic and demographic changes over time. Worked with local advisory committee to craft goals and recommended actions for plan implementation. Managed team that development of Natural Resources Inventory for examination of development proposals by local Environmental Conservation Board. Zoning Amendments- Directed the team that researched local land use patterns and development trends, and identification of options for land protection and development strategies. Worked with Town staff and board members to shape improve existing conservation subdivision ordinance Underground Railroad Heritage Area Management Plan (HAMP), City of Niagara Falls, NY- Directed the team that researched existing economic and demographic conditions within Niagara County. Managed team that researched history of Underground Railroad that helped shape management strategies. The HAMP was authorized under Section 35.05 of the New York State Parks, Recreation, and Historic Preservation Law to identify and encourage heritage tourism opportunities related to Underground Railroad in the vicinity of Niagara Falls District. Three Rivers Point Waterfront Access Study, Syracuse Metropolitan Transportation Council, Town of Clay, NY- Directed the team that provided planning and design services to determine best use for 75 acres of prime waterfront land located at the intersection of the Oswego, Seneca and Oneida Rivers. The property is an abandoned oil transfer station. In Phase 1, a conceptual master plan was developed to depict a mixed-use development. The plan also recommended public space and access to the water, along with a sensitive approach to the historic and cultural values of the Town and the site. As a result, the Town received funding to mitigate the Brownfield and demolish deteriorated buildings to make the site more attractive to investment. Local Waterfront Revitalization Plan (LWRP), Town of DeWitt, NY- Directed the EDR team that was collaborating with the town of DeWitt to prepare a plan for the revitalization of the waterfront along the NYS Canal System. The plan is proposed to include: visioning for the historic canal corridor, assessment of development patterns, identification of land and water use controls, and development of revitalization policies and implementation strategies. Work will include planning for a segment of the canal way trail that would close the gap between the Town of Dewitt and the Town of Camillus. ReZone Syracuse, City of Syracuse, NY- Directed EDR team assigned to support a nationally-recognized land use consulting firm to draft a new zoning code for the City of Syracuse. Project objectives include: (1) ensure the new ordinance and map implement the recommendations of the Comprehensive Plan 2040, including the Syracuse Land Use & Development Plan 2040; (2) transition from the current use-focused, Euclidian zoning ordinance to an updated ordinance that incorporates principles of Form Based Codes, and Smart Growth; (3) develop and/or improving standards regulating urban design, urban agriculture, lighting, signage, landscaping, parking, site design, infill development, and vacant land management; (4) promote and facilitate historic preservation; (5) develop sustainable development provisions regarding: climate adaptation, renewable energy infrastructure, green building standards, and green infrastructure; (6) increase protection of natural resources; (7) streamline the development review process by creating more predictable zoning regulations; (8) update the format and structure of the zoning ordinance to be user-friendly and include graphics and illustrations; (9) remove inconsistencies, outdated language, and reducing the complexity of the zoning ordinance; (10) facilitate increased public awareness of, and participation in zoning reviews and processes; and (11) increase ways to use technology to provide and receive information from the public. EDR is leading the update of the zoning map, participating in public engagement and education, implementing character area recommendations noted in the municipal land use plan, and drafting the landscape standards section of the new ordinance. Syracuse Metropolitan Transportation Authority, Transit Study Phase 1 (SMART 1) (on behalf of the Central Regional Transportation Authority), Syracuse, NY- Directed EDR team assigned to provide community planning services, that include outreach and engagement activities to a team of national consultant to advance recommendations identified in the Syracuse Transit Analysis to pursue a higher-intensity transit services along the Destiny/Regional Transportation Center to Syracuse University and James Street/South Avenue corridors. Lakefront Regulating Plan & Zoning Code Revisions, City of Syracuse, NY- Managed and worked alongside the EDR team assigned to ensure that improvements to the 1,200‐acre Onondaga Lakefront would be developed using the principles of New Urbanism. EDR applied Form‐Based Code techniques to revise the zoning for this area. The new code emphasized the character of the streets and other public spaces, and a mixture of land uses including retail, office, technology, light industry, waterfront recreation, and residential. EDR provided extensive community outreach. Hybrid code was adopted and integrated into the existing zoning code Multiple Dwellings Study, Town of Henrietta, NY- Directed EDR team assigned to provide planning expertise related to an in-depth review and analysis of existing land use plans and regulations, and to develop proposed zoning amendments related to multiple dwellings and other land uses within the Town of Henrietta.

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Empire State Development, Downtown Revitalization Plans, Round 1- Oversaw EDR team that assisted with design (focusing on waterfront improvements) for City of Jamestown, and with zoning for the City of Oswego and Elmira. Round 2 – Oversaw EDR team that assisted with design (focusing on waterfront improvements) for City of Hudson, and with zoning and permitting for the City of Cortland. New York Rising Community Reconstruction Plan, Herkimer, Madison, & Oneida County, NY- Directed the New York Rising Community Reconstruction Program that was established by the New York State Department of State in the wake of several severe weather events including Hurricanes Sandy and Irene, Tropical Storm Lee, and the devastating floods of 2013. The program leverages state investments to assist with reconstruction projects directed toward damaged infrastructure, as well as other projects that are intended to mitigate against future risks and increase their resiliency in the face of future storm events. As a member of the consulting team EDR assisted with community outreach throughout Madison, Oneida, and Herkimer Counties, where back-to-back storms flooded entire communities twice within three days – washing out roads, bridges, utilities, and other infrastructure. The New York Rising Countywide Resiliency Plan (for each county) represents the first steps that the county and state will take toward implementing priority projects, and ultimately creating a more resilient Madison, Oneida, and Herkimer County. Governor’s Office of Storm Recovery, Village of Waterfront Resiliency Program, NY- Directed EDR to provide community engagement services to focus stakeholders in moving community planning and capacity building, economic development, health and social services, housing, infrastructure, natural and cultural resource recovery projects, programs, and actions forward under the NYRCR Planning Program. Onondaga County Multi-Jurisdictional Hazard Mitigation Plan Update- Oversaw EDR team providing community outreach and engagement services. The purpose of this project is to provide consultant services to update the Plan for Onondaga County and 35 participating municipalities and jurisdictions. The final plan must also meet Federal and State requirements and be approved by the Federal Emergency Management Agency and the NYS Division of Homeland Security and Emergency Services. Genesee Transportation Council, Ontario Lake Parkway Transportation Alternatives Feasibility Study, Towns of Kendall & Carlton, Orleans County, NY- Managed land use planning and design, needs assessment, and community engagement services to support the determination of the feasibility of re-purposing, in whole or part, the eastbound and/or westbound lanes of approximately 12.7-miles of Lake Ontario State Parkway. The deteriorating condition of the westernmost portion of the Parkway, has raised legitimate concerns about the long-term viability of its continued operation as a divided, four-lane highway. The proposed project will investigate whether it is financially feasible to re-purpose or decommission the eastbound and westbound lanes or portions thereof, while still providing an appropriate facility for vehicle demand. Old Erie Canal Corridor Local Waterfront Revitalization Program (LWRP), NYSDOS, Madison County, NY- Directed the EDR team collaborating with Madison County to prepare a plan for reimaging the Old Erie Canal Corridor. The plan is proposed to include: visioning for the historic canal corridor, assessment of development patterns, identification of land and water use controls, and development of revitalization policies and implementation strategies. Local Waterfront Revitalization Program (LWRP) Update, NYSDOS, City of Binghamton, Broome County, NY- Directed the EDR team collaborating with the City of Binghamton to update the LWRP to reflect current local conditions including significant new development, and to include recommendations and projects that build greater community resilience to natural hazards and resurrect housing and businesses damaged by recent flooding events. An approved LWRP will guide sustainable development, increase utilization of the waterfront, and promote economic development to improve the overall quality of life for residents and visitors. This project also includes preparation of National Flood Insurance Program (NFIP) Community Rating System for the City, a program that recognizes community floodplain management activities that exceed the minimum NFIP requirements and is necessary to occur as part of any waterfront management plan. publications / presentations Presenter, Onondaga County Planning Federation, McIntyre Commons: A Case Study in Brownfield Redevelopment, Community Character, and Environmental Integrity, March 5, 2015 Presenter, Onondaga County Planning Federation, Form-Based Zoning: A Creative Approach, March 13, 2014 Presenter, Onondaga County Planning Federation, Sustainable Land Use Planning & Resource Conservation Strategies, March 14, 2013 Panelist, GreeningUSA Green Bag Lunch Series, Sustainable Land Use Planning & Resource Conservation Strategies, 2013. Presenter, Sustainable Community Planning, APA/ASLA Upstate NY Chapters Joint-Conference, Utica NY, September 2011. Presenter, Land Use Planning Workshop, The Benefits of Sustainable Community Planning & Design, Jefferson Community College Center for Community Studies, 2011. Land Use Training Workshop for Herkimer-Oneida Counties, Herkimer-Oneida Counties Comprehensive Planning Program, 2010.

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Jane E. Rice, JD, Principal Director of Planning

Land Use Planning Workshop for Jefferson County, 2009. Annual Planning Symposium for the Onondaga County Planning Federation, Syracuse, NY, 2008 and 2009.

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NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

KEVIN VAN HISE, PLA

KIMLEY-HORN OF NEW YORK, P.C.

Case No. 17-F-0655 VAN HISE

1 Q: Please state your name, employer, and business address.

2 A: Kevin Van Hise PLA, Kimley-Horn of New York, P.C., 1 North Lexington Avenue, Suite 1575,

3 White Plains, New York, 10601

4 Q: What is your position at Kimley-Horn of NY?

5 A: I am a Senior Landscape Architect.

6 Q: How long have you been employed with Kimley-Horn of NY?

7 A: 12 years, I have been employed with KH since 2008.

8 Q: Please describe your educational background and professional experience.

9 A: I received a Bachelor of Science in Landscape Architecture from The Pennsylvania State University

10 in State College, Pennsylvania. I am a licensed Landscape Architect in New York, New Jersey and

11 Pennsylvania. I have 30 years of experience designing and overseeing private and public site

12 development projects involving large scale grading operations, vegetative buffering and screening,

13 wetland mitigation, riparian buffers and landscape master plans. Additional information on my

14 experience is presented in my curriculum vitae (CV), which is included as Exhibit ____ (KVH-PF1):

15 Resume of Kevin Van Hise.

16 Q: Please describe your current responsibilities with Kimley-Horn of NY.

17 A: As the Senior Landscape in the northeast I oversee and participate in all landscape architectural

18 related tasks in the White Plains office as well as our Princeton NJ and Philadelphia PA offices.

19 This consists of a wide range of design tasks but of relevance to my testimony in this matter, I have

20 prepared landscape buffer design plans associated with large scale developments in

21 environmentally sensitive, rural landscapes in New York.

22 Q: Have you previously testified before the New York State Public Service Commission or

23 Siting Board on Electric Generation?

24 A: No.

Page 2 of 3

Case No. 17-F-0655 VAN HISE

1 Q: Have you previously served as an expert witness before any other court, agency, or other

2 body on the subject you plan to offer testimony on today?

3 A: Yes, I have served as an expert witness before Zoning Boards of Appeal, Planning Commissions

4 and Town and Village Boards throughout New York, New Jersey and Pennsylvania about

5 landscape screening and visual impact.

6 Q: What is the purpose and scope of your testimony in this proceeding?

7 A: To sponsor certain portions of the Riverhead Solar 2 Application or the Exhibits thereto.

8 Q: What portion(s) of the Application is your testimony sponsoring?

9 A: Portions of Exhibit 11 and facility design related to landscape design.

10 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

11 direction and supervision.

12 A: Yes.

13 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

14 or documents produced by persons other than yourself/your company? If so, please cite

15 these sources.

16 A: Relevant references, if any, are cited in the Exhibit and associated Appendices and Figures.

17 Q: Does this conclude your testimony?

18 A: Yes.

Page 3 of 3

Kevin Van Hise, PLA, ASLA Landscape Architect

Kevin has 29 years of experience in planning and landscape architecture. His experience includes legislative planning and zoning applications, construction plans, and site plans for private and public K-12 educational projects. Throughout his career, Kevin has excelled at leading large, multidisciplinary teams to provide sustainable solutions to complex problems and challenging sites. He has Professional extensive experience with public design charrettes—routinely using his Credentials design and illustration skills to build public consensus toward a common goal Bachelor of Science, or design solution. Landscape Architecture, Sample Experience Pennsylvania State

University, 1990 ⚫ Riverhead II Solar, Riverhead, NY — Project Manager ⚫ Upstate New York Casino Bid Application, NY — Landscape Architect Professional ⚫ Sunshine Children's Home, New Castle, NY — Landscape Architect Landscape Architect ⚫ Newark Street Intersection Safety Improvements, Hoboken, NJ — (New York, and New Landscape Architect Jersey) ⚫ Northwest Pop-Up Park and Temporary Municipal Parking Lot, Hoboken, NJ — Landscape Architect Professional ⚫ Engineering Design Services for Windmill Hill Bulkhead Improvements, Organizations Alexandria, VA — Project Manager American Society of ⚫ Hood College, West Campus Improvements, Frederick, MD — Project Landscape Architects Manager

⚫ District of Columbia Office of Public Facilities Modernization (OPEFM), 10th Street Park Design, Washington, DC — QC/QA Reviewer ⚫ Jefferson-Houston Pre-Kindergarten—8 School, Alexandria, VA — Project Manager ⚫ Cora Kelly Playground, Alexandria, VA — Project Manager ⚫ TC Williams High School Tennis Courts, Alexandria, VA — Project Manager. ⚫ FC Hammond Middle School Field Replacement, Alexandria, VA — Project Manager ⚫ Ben Brenman Park Synthetic Turf Field Replacement and Athletic Field Lighting, Alexandria, VA — Project Manager

KVH-PF1 Page 1 of 1 NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

MOHAMED EL CHEHALY, Eng., M.Eng.

MANAGER, GRID SOLUTIONS

SNC-LAVALIN

Case No. 17-F-0655 EL CHEHALY

1 Q: Please state your name, employer, and business address.

2 A: Mohamed El Chehaly, SNC-Lavalin, 1801 McGill College, Montreal, Quebec, Canada H3A 2N4.

3 Q: What is your position at SNC-Lavalin?

4 A: Manager, Grid Solutions.

5 Q: How long have you been employed with SNC-Lavalin?

6 A: I have been employed with SNC-Lavalin since 2010.

7 Q: Please describe your educational background and professional experience.

8 A: I received a Bachelor in Electrical Engineering from Concordia University, Montreal, Quebec,

9 Canada. I also received a Masters of Engineering in Electrical Engineering from McGill University,

10 Montreal, Quebec, Canada. I have 11 years of experience in electrical engineering experience within

11 the distinct areas of power system planning, HVDC and FACTS, and cable studies. I currently

12 manage the Grid Solutions team for SNC Lavalin. A copy of my resume is submitted as Exhibit ____

13 (ME-PF1): Resume of Mohamed El-Chehaly.

14 Q: Please describe your current responsibilities with SNC-Lavalin.

15 A: I am responsible for system studies, interconnection studies, market studies and act as a Subject

16 Matter Expert on interconnection studies for projects in New York, New England, New Jersey,

17 Delaware and California.

18 Q: Have you previously testified before the New York State Public Service Commission or

19 Siting Board on Electric Generation?

20 A: I previously adopted and supported testimony in the following proceedings:

21 • Application of Flint Mine Solar, LLC Case No. 18-F0087

22 • Application of Mohawk Solar LLC Case No. 17-F-0182

Page 2 of 3

Case No. 17-F-0655 EL CHEHALY

1 Q: Have you previously served as an expert witness before any other court, agency, or other

2 body on the subject you plan to offer testimony on today?

3 A: No.

4 Q: What is the purpose and scope of your testimony in this proceeding?

5 A: To sponsor certain portions of the Solar Riverhead Solar 2 Project Application or the Exhibits

6 thereto.

7 Q: What portion(s) of the Application is your testimony sponsoring?

8 A: Exhibit 8, Electric System Production Modeling and related Appendices.

9 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

10 direction and supervision.

11 A: Yes.

12 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

13 or documents produced by persons other than yourself/your company? If so, please cite

14 these sources.

15 A: See Exhibit 8 and the related Appendices for any references.

16 Q: Does this conclude your testimony?

17 A: Yes.

Page 3 of 3

MOHAMED EL CHEHALY, Eng., M.Eng.

Mr. Mohamed El Chehaly has eleven years of electrical engineering experience within the distinct areas of power system planning, HVDC and FACTS, and cable studies. Mr. El Chehaly is currently managing the Grid Solutions team in Montreal. His commitment to quality and on-time delivery has made him a go-to resource for clients. He has led numerous programs for the transfer of technology aimed at developing in-house expertise in system studies and planning for utilities across the globe. His unique development of automated scripts and work processes ensures a lean and flexible delivery of data-intensive studies. Mr. El Chehaly is highly knowledgeable in PSS®E and PSCAD modeling, HVDC functional specifications and control strategies, as well as the full range of network studies including voltage stability, transient stability, transfer studies, load and IPP interconnections, and harmonic studies. His research background encompasses distributed generation, wind penetration, plug-in hybrids and active methods to detect islanding. Mr. El Chehaly holds a master degree in electrical engineering, and is currently working within SNC-Lavalin Clean Power, alongside a team of system studies experts with over 40 years of experience.

SECTORS OF EXPERTISE Years of Experience Complementary sectors › Professional / Consulting Services; System analysis; Systems › 13 years (development, control, simulation) Power › Power Transmission and Distribution; Power System Planning; Wind, Solar and Tidal Power; Training and Transfer of Years with SNC-Lavalin Technology › 11 years

EDUCATION Key Positions M. Eng. in Electrical Engineering, Option: Thesis Power System Stability Analysis with 2010 › Engineer - Electrical High Penetration of Distributed Generation, McGill University, Montreal, Quebec, › Engineering Systems Canada Specialist 2008 Bachelor in Electrical Engineering, Option: Electronic, Concordia University, Montreal, › Planning Analyst Quebec, Canada

Languages EXPERIENCE › English SINCE 2010 SNC-LAVALIN INC., MONTREAL, QUEBEC, CANADA › Arabic Since 2018 Manager, Grid Solutions › Spanish

System Studies Lead, Offshore Wind Farm Interconnection, Confidential, United › French States (04/2018 - present) › Italian

› Supervised the memos submitted to the utility discussing the reactive power capability of the plant › Helped prepare the interconnection request › Supervised technical memos provided to the manufacturer › Responsible for coordinating the dynamic studies performed by another Consultant

System Studies Lead, Several Renewable Projects in the USA, Confidential, United States (04/2018 - present)

› Performed and supervised several injection studies in NYISO, ISONE and PJM › Supervised production modeling for several projects in NYISO › Selected several potential points of interconnection for new renewable projects

2018/10 Page 1 / 6 CURRICULUM VITAE

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MOHAMED EL CHEHALY, Eng., M.Eng.

› Prepared PSSE models for renewable projects › Supervised PSCAD models preparation for renewable projects Site Experience › Filed several Interconnection Requests for large and small generators in ISONE › Canada › Interacted directly with manufacturers to ensure that the models represent the › Qatar performance of the actual equipment › Saudi Arabia Energy › Tanzania 2016 - 2018 Lead Planning Engineer, Grid Solutions

System Studies Lead, Offshore Wind Farm Interconnection, Confidential, United Computer Applications States (07/2017 - present) › Languages: Visual Basic › Performed studies for project interconnection and permitting such as Reactive 6.0, C, C++, MC68000 Power Studies, Cable Ampacity Calculations for underground cables › Supported creation of the Basis of Design Assembler, Python, › Coordinated with the cable engineer to select the cable sizes FORTRAN › Supervised submarine cable ampacity calculations › Software Applications: Microsoft Word, Microsoft Excel, Microsoft Power Engineering Technical Lead and Transmission Planner, GTC-601, CONSULTANCY Point, Microsoft Access SERVICES FOR QATAR’S LONG-TERM ELECTRICITY TRANSMISSION › Environments: XWindows, DEVELOPMENT PLAN, KAHRAMAA (QATAR GENERAL ELECTRICITY & WATER Linux/Unix CORPORATION), Planning, KAHRAMAA, Qatar (03/2016 - 03/2017) › CAD: Analog (Analog The objective of the Consultancy is the development of Qatar’s long term electricity Workbench), Cadence transmission development plan to meet the peak-load demand consistent with Qatar Analog Artist, PSPICE, Vision of 2030. MATLAB/SIMULINK, - Assisted Project Manager in supervising technical reports from all disciplines and PSIM, PowerWorld, EM coordinating between disciplines › Lab Equipment: Tektronix - Review of load forecasting and generation planning reports Oscilloscope, Lab-Volt, - Conducted a generation interconnection study - Responsible for transmission planning andreactive power and load modelling study Hewlett Packard Logic - Assisted in the planning criteria development Analyzer, dSPACE, Opal- - Responsible for Client training RT, RT

Power Transmission & Distribution - Montreal 2010 - 2016 Power System Engineer, Centre of Excellence in Planning & Studies

Engineering Technical Lead and Transmission Planner, GTC-601, CONSULTANCY SERVICES FOR QATAR’S LONG-TERM ELECTRICITY TRANSMISSION DEVELOPMENT PLAN, KAHRAMAA (QATAR GENERAL ELECTRICITY & WATER CORPORATION), Qatar (03/2015 - 03/2016)

The objective of the Consultancy is the development of Qatar’s long term electricity transmission development plan to meet the peak-load demand consistent with Qatar Vision of 2030.

- Assisted Project Manager in supervising technical reports from all disciplines and coordinating between disciplines - Review of load forecasting and generation planning reports - Conducted a generation interconnection study - Responsible for transmission planning and reactive power and load modelling study - Assisted in the planning criteria development

2018/10 Page 2 / 6 CURRICULUM VITAE

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MOHAMED EL CHEHALY, Eng., M.Eng.

- Responsible for Client training

FACTS Lead, Chapel Rock DRPC (Dynamic Reactive Power Control) Device, AltaLink, L.P., Alberta, Canada (12/2014 - 06/2015)

Chapel Rock substation connects the 500 kV intertie between Alberta and British Columbia. The purpose of the DRPC device at the Chapel Rock substation is to provide dynamic reactive power to regulate the 240 kV bus voltage under normal and contingency conditions, and in order to compensate fluctuations due to nearby wind generation. As part of a larger mandate, SNC-Lavalin is providing owner engineering services for the DRPC Early Market Test.

Responsible for the following: - Reviewing the Preliminary Specification - Conducting the Harmonic Impedance Study - Preparing the Early Market Test summary report including analyzing the Early Market Test pre-bids from two manufacturers. - Preparing the Detailed Rating Specifications for the DRPC - Reviewing the AltaLink SVS General Technical Specifications - Participating in the Risk Assessment meetings

500kV Edmonton to Calgary Western Alberta Transmission Line (WATL), AltaLink LP, Canada, CA $1 136 000 000, 1 000 MW at 500kV (Stage-1) (06/2013 - 12/2015)

The main scope of works includes the construction of two (02) 1000MW 500kV HVDC Converter Stations along with the HVAC switchyards and 347kM 500kV HVDC transmission line between Genesee and Langdon area.

› Tested the PSS®E load-flow and dynamic models of HVDC and STATCOM › Assisted in testing the PSCAD models of HVDC and STATCOM › Compared the PSS®E and PSCAD models with the HVDC Control Systems and Strategies Reports

Consultancy Services for SEC Interconnection Tie Lines Transfer Limits Planning Study 2016-2020, Saudi Engineering Group International, Saudi Arabia, CA $281 300 (06/2012 - 2015)

Planning study for the period 2016-2020 for the determination of the Power Transfer limits of the 380kv Transmission interconnection among SEC's Central,Eastern,Western and Southern Operating areas.

› Managed a team of three Engineers an Specialists to conduct the study; › Responsible for load flow, short-circuit and stability studies consisting of determining the maximum transfer through each inter-tie between the main sectors (Central Operating Area, Western Operating Area, Eastern Operating Area, Southern Operating Area …) for each study year; › Provided the Client trainings on power system studies; › Developed an HVDC model for a future HVDC line using PSS®E; › Proposed reinforcements such as a 600 MVAR SVC to increase transfer between regions; › Provided the Client an adequacy report to show the main issues of the system for each study year; and › Conducted additional studies in areas where reinforcements are required.

Power System Stability Calculation Training, National Load Dispatch Centre (NLDC), Canada, CA $99 000 (06/2013 - 12/2013)

The scope of this project is to train the Client’s personnel to be experts in power system stability and to have the capability to solve all issue related to stability.

› Project Manager and Study Specialist for the Training of 16 Vietnam Electricity (EVN) personnel that lasted 6 weeks; › Provided a detailed training on voltage stability, angular stability, frequency stability, small signal stability and long-term stability;

2018/10 Page 3 / 6 CURRICULUM VITAE

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MOHAMED EL CHEHALY, Eng., M.Eng.

› Provided a detailed training on tools used to analyze all types of stability; › Investigated possible stability problems in the Vietnamese system; › Provided possible solutions and discussed them with the participants; › Provided a detailed training on automation of stability studies; › Explained the role of shunt and series compensation, FACTS devices and other equipmenet in the improvement of power system stability; › Discussed the impact of excitation and governor systems on the system stability; and › Coordinated the arrangement for 16 participants to attend the training in Montreal.

Muskrat Falls Hydroelectric Development, Nalcor Energy, Canada, CA $6 000 000 000, 824 MW (04/2011 - 2012)

› Responsible for load flow, short-circuit and stability studies; › Incorporated and simulated a new 350 kV, 900 MW HVdc bipolar lines between Newfoundland and Labrador and 250 kV, 500 MW bipolar lines between Newfoundland and Nova Scotia; › Developed HVDC models in PSS(R)E with basic controllers; › Performed a system study for the construction of the future substation at Muskrat Falls; › Contributed in reactive and harmonic studies for the new HVdc converter stations; › Conducted transient recovery voltage studies on the generator circuit breakers; and › Responsible for coordination of voltage control equipment (switched capacitor banks, on-load tap changers …).

Bahrain Land Cable, Ministry of Electricity & Water, Bahrain (2011)

› Conducted several studies to determine the minimal distance of placing land cables near the 400 kV cable buried in Bahrain; and › Determined also the possibility of placing three three-phase 66 kV cables in trough filled with thermal sand.

Eastern Africa Power Pool Regional Power System Master Plan and Grid Code Study, Eastern Africa Power Pool (EAPP), Burundi, CA $1 003 650 (2010 - 2011)

› Performing transmission planning and system studies (load flow, short-circuit and transient stability studies) for the ten African countries (Burundi, Djibouti, Democratic Republic of Congo, Egypt, Ethiopia, Kenya, Rwanda, Sudan, Tanzania and Uganda); › Developing system reinforcements depending on the future interconnections between these countries in 2038; › Assuring the stability of each system from 2009 to 2038; and › Provided training to all participant countries on system studies in Tanzania.

Consultancy Services to Assist in the Development of Electricity Generation and Transmission Plan, King Fahd University of Petroleum and Minerals (KFUPM), Saudi Arabia, CA $436 327 (2010 - 2011)

Electricity demand forecast, and financial analysis of the Master Plan for the expansion of the generation and transmission systems in Saudi Arabia.

› Responsible for developing the Saudi transmission system until 2032; › Developed power system cases from the years 2010 to 2032 with all the required reinforcements; and › Conducted load flow studies, short-circuit studies as well as stability studies for peak and light load conditions.

HVDC Interconnection Project between Egypt and Saudi Arabia, Egyptian Electricity Holding Company (EEHC), Egypt, CA $4 238 520 (2010)

2018/10 Page 4 / 6 CURRICULUM VITAE

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MOHAMED EL CHEHALY, Eng., M.Eng.

› Responsible for developing equivalent networks for each system with different scenarios. Considering that the real- time simulator can only store a limited number of buses and generators, equivalent circuits are developed around the buses with the HVDC interconnection.

Parallel Operation Study for Glenannan Substation Transformers, British Colombia Transmission Corporation, Canada (04/2010 - 04/2010)

› Responsible for conduction the power system studies to interconnect a new transformer in parallel and to ensure successful coordination between the old and the new transformers.

Ajax Mine Load Interconnection – System Impact Study, British Colombia Transmission Corporation, Canada (04/2010 - 04/2010)

› Responsible of proposal preparation for a load interconnection study for BCTC.

Cordel to Hansman Lake 240 kV Transmission Line and Substation, AltaLink LP, Canada, CA $39 900 000, 240 kV (2012)

103 km of new 240 kV transmission line. One new 240/138/25 kV substation (Hansman Lake). Reconstruction of an existing 240/138/25 kV susbtation (Metiskow). Communication upgrades.

Hansman Lake 200 MVAR Static Var Compensator. › Tested the PSS®E model using the tests conducted in PSCAD

2008 - 2009 MCGILL UNIVERSITY, MONTREAL, QUEBEC, CANADA Researcher

› Electrical and Computer Engineering, McGill University, Montreal − Modeled a 25kV test case and tested it with anti-islanding using active methods, − Studied the voltage stability of the system with large penetration of distributed generation (PSS®E), − Implemented indices to emphasize on the impact of large penetration of distributed generation on the short-term and the long-term voltage stability (PSS®E), − Worked with other researchers on wind penetration and plug-in hybrid cars.

2008 - 2009 ECOLE POLYTECHNIQUE, MONTREAL, QUEBEC, CANADA Teaching Assistant

› Power Electronics (IGEE 401) Fall 2008, › Appareillages Électriques et Matériaux (IGEE 410) Winter 2009, − Conducted lab sessions,corrected assignments and assisted students to industrial visits

2006 - 2007 ABB, SAUDI ARABIA Internship

› Automation Products (July-August 2006) − Monitored the design of motor drives, power converters and synchronizing products › Electrical Power Products & Power Systems (July-August 2007) − Monitored the design of transformers and switchgears

2018/10 Page 5 / 6 CURRICULUM VITAE

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MOHAMED EL CHEHALY, Eng., M.Eng.

PROFESSIONAL ASSOCIATIONS

SINCE 2015 Ordre des ingénieurs du Québec (OIQ)

PUBLICATIONS AND PRESENTATIONS

H. A. Gil, M. El Chehaly, G. Joos, C. Cañizares, “Bus-based Indices for Assessing the Contribution of DG to the Voltage, Security Margin of the Transmission Grid” IEEE Power & Energy Society 2009 General Meeting, Calgary, Alberta, Canada, 2009 M. El Chehaly, H. A. Gil, G. Joos, “Impact of Distributed Generation on Voltage Security Margin Using Bus-based Indices”, 2009 CIGRÉ Canada Conference on Power Systems, Toronto, Ontario, Canada, 2009 M. El Chehaly, O. Saadeh, C. Martinez, G. Joos, “Advantages and Applications of Vehicle to Grid Mode of Operation” Electrical Power and Energy Conference 2009, Montreal, Quebec, Canada, 2009

AWARDS AND SCHOLARSHIPS

2007 Scholarship, Hydro-Quebec, Montreal, Quebec, Canada

2006 CAE Scholarship in Engineering Excellence, CAE, Montreal, Quebec, Canada

2018/10 Page 6 / 6 CURRICULUM VITAE

MEC-PF1 Page 6 of 6

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

MICHAEL FARRELL

SPOWER – RIVERHEAD SOLAR 2

Case No. 17-F-0655 FARRELL

1 Q: Please state your name, employer, and business address.

2 A: Michael Farrell; sPower / Riverhead Solar 2; 195 Montague Street, 14th Floor, Suite 1461,

3 Brooklyn, NY 11201

4 Q: What is your position at sPower?

5 A: I am a Senior Manager, Solar Development.

6 Q: How long have you been employed with sPower?

7 A: I joined sPower in September 2019.

8 Q: Please describe your educational background and professional experience.

9 A: I received a Bachelor of Science in Business Administration from the University of Connecticut in

10 1996, and a Master in Business Administration from Carnegie Mellon University (Tepper School of

11 Business) in 2008. After receiving my undergraduate degree I worked in public accounting in CT,

12 Switzerland, and the United Kingdom. After receiving my MBA, I started working in renewable

13 energy, first for a developer of utility-scale wind projects called EverPower Wind Holdings, Inc., where

14 I was leading the project finance and M&A teams. I then worked for GE Energy Financial Services

15 leading teams that were underwriting tax equity investments for wind and solar projects. After GE

16 EFS, I joined a start-up called United Wind, Inc. as their Chief Financial Officer. In 2018 I started

17 external consulting for the NY Green Bank where I assisted with project finance engagements for

18 wind and solar projects. In September 2019 I joined sPower in New York as a Senior Manager, Solar

19 Development. A copy of my resume is submitted as Exhibit ____ (MF-PF1): Resume of Michael

20 Farrell.

21 Q: Please describe your current responsibilities with sPower.

22 A: I lead development of solar, wind, and energy storage projects in New York for sPower out of

23 sPower’s Brooklyn office.

Page 2 of 3

Case No. 17-F-0655 FARRELL

1 Q: Have you previously testified before the New York State Public Service Commission or

2 Siting Board on Electric Generation?

3 A: No

4 Q: Have you previously served as an expert witness before any other court, agency, or other

5 body on the subject you plan to offer testimony on today?

6 A: No

7 Q: What is the purpose and scope of your testimony in this proceeding?

8 A: To sponsor certain portions of the Riverhead Solar 2 Application or the Exhibits thereto.

9 Q: What portion(s) of the Application is your testimony sponsoring?

10 A: Exhibit 1: General Requirements, Exhibit 2: Overview and Public Involvement, Exhibit 3: Location

11 of Facilities, Exhibit 5: QA/Q Plan; Exhibit 10: Consistency with Energy Planning Objectives, Exhibit

12 12: Construction, Exhibit 13: Real Property, Exhibits 14: Cost of Facilities, Exhibits 15: Public

13 Health and Safety; Exhibit 18: Safety and Security; Exhibit 29: Site Restoration and

14 Decommissioning, Exhibit 31: Local Laws and Ordinances, Exhibit 32: State Laws and

15 Regulations, Exhibit 33: Other Applications and Filings.

16 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

17 direction and supervision.

18 A: Yes.

19 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

20 or documents produced by persons other than yourself/your company? If so, please cite

21 these sources.

22 A: The relevant references are contained in the above-mentioned Exhibits.

23 Q: Does this conclude your testimony?

24 A: Yes.

Page 3 of 3

MICHAEL G. FARRELL New York, NY – [email protected]

PROFESSIONAL EXPERIENCE sPower (an AES and AIMCO Company) Senior Manager, Solar Development; New York, NY (2019 – Present)  Lead renewable energy project development in New York for a leading IPP that owns and operates a leading solar, wind, and storage portfolio of nearly 2.0 GW, with 15 GW of projects under development across the U.S.

NY Green Bank (a division of NYSERDA) Consultant; New York, NY (2018 – 2019)  Provided project finance expertise (due diligence, terms negotiation, credit approval support, and legal documentation) for wind and solar lending as a consultant on renewable energy for the largest Green Bank in the U.S.

United Wind, Inc. Chief Financial Officer; New York, NY (2017 – 2018)  Led finance and operations teams through challenging reorganization, and implemented pivot to an outsourced wind project construction and O&M structure for a distributed wind energy start-up offering an innovative lease product for small wind turbines.

GE Capital, Energy Financial Services Vice President, Renewables Underwriting; Stamford, CT (2014 – 2016)  Spearheaded the close of $250+ million in tax equity investments in 550MWs of renewable energy projects, and held full accountability for overseeing and managing 10+ member deal underwriting teams charged with leading transaction structuring, negotiations, and closing of transactions.

EverPower Wind Holdings, Inc. (EverPower) Managing Director, Finance; New York, NY (2014) Director, Finance; New York, NY (2011 – 2014) Finance Manager, Business Development; New York, NY (2010 – 2011) Commercial Manager; New York, NY (2008 – 2010)  Drove growth from zero to seven operating projects, totaling 750+MWs, by leading the external financing and M&A initiatives for a developer, owner, and operator of utility-scale wind projects.

Constellation Energy Analyst, Corporate Strategy (Summer Intern); Baltimore, MD (2007)  Developed and delivered a business plan detailing a new service offering in renewable energy installations, including solar, wind, biomass, landfill gas, and fuel cells.

MF-PF1 Page 1 of 2 Michael Farrell Resume – June 2020

KPMG LLP (Europe) Manager, Transaction Services; London, United Kingdom (2003 – 2006) Manager, U.S. GAAP Advisory Services; Zurich, Switzerland (2000 – 2003)  Directed teams in technical accounting projects, SEC registrations, due diligence, financial audits, business plan reviews, designing financial models, and analyzing projections and working capital requirements for public and private companies in the consumer, industrial, real estate, insurance, and healthcare markets.

KPMG LLP (U.S.) Supervising Senior, Audit; Stamford, CT (1999 – 2000)  Provided audit and review services for public and private companies. Prepared fully disclosed financial statements in accordance with U.S. GAAP.

Dworken, Hillman, LaMorte & Sterczala, P.C. (DHL&S) Senior, Audit & Tax; Bridgeport, CT (1997 – 1998)  Conducted audits and reviews for companies across a variety of industries, including a publicly-listed water utility, and completed federal and state tax returns for corporations, partnerships, and individuals.

EDUCATION & DESIGNATION

 Carnegie Mellon University, Tepper School of Business, Pittsburgh, PA Master of Business Administration

 University of Connecticut, Storrs, CT Bachelor of Science in Business Administration; Major in Accounting

 Designation: Certified Public Accountant (CPA) in the State of Connecticut

Page 2 of 2 MF-PF1 Page 2 of 2 NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

MUKTAR H. KHATARI, P.E.

GZA GEOENVIRONMENTAL OF NEW YORK

104 WEST 29TH STREET, NEW YORK, NY 10001

Case No. 17-F-0655 KHATARI

1 Q: Please state your name, employer, and business address.

2 A: Muktar H. Khatari, GZA GeoEnvironmental of NY, 104 W 29th St, 10th floor, NYC NY 10001.

3 Q: What is your position at GZA?

4 A: Associate Principal.

5 Q: How long have you been employed with GZA?

6 A: 21 years..

7 Q: Please describe your educational background and professional experience.

8 A: Bachelor of Civil Engineering, Polytechnic University, Brooklyn, NY. Professional Engineer in the

9 State of New York. A copy of my resume is submitted as Exhibit ____ (MHK-PF1): Resume of Muktar

10 H. Khatari.

11 Q: Please describe your current responsibilities with GZA.

12 A: Senior Geotechnical Engineer in the NYC Office.

13 Q: Have you previously testified before the New York State Public Service Commission or

14 Siting Board on Electric Generation?

15 A: No.

16 Q: Have you previously served as an expert witness before any other court, agency, or other

17 body on the subject you plan to offer testimony on today?

18 A: No.

19 Q: What is the purpose and scope of your testimony in this proceeding?

20 A: To sponsor certain portions of the Solar Riverhead Solar 2 Project Application or the Exhibits

21 thereto.

22 Q: What portion(s) of the Application is your testimony sponsoring?

23 A: Exhibit 21: Geo-technical Report.

Page 2 of 3

Case No. 17-F-0655 KHATARI

1 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

2 direction and supervision.

3 A: Yes.

4 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

5 or documents produced by persons other than yourself/your company? If so, please cite

6 these sources.

7 A: No.

8 Q: Does this conclude your testimony?

9 A: Yes.

Page 3 of 3

Muktar H. Khatari, P.E. Associate Principal

Summary of Experience

Mr. Khatari has over 20 years of experience in the field of geotechnical engineering. His

work experience includes the organization, management, and supervision of

geotechnical and foundation design projects. Tasks include supervision of personnel, preparation of geotechnical designs and reports for foundations and substructure elements, and the organization and supervision of subsurface exploration work, subsurface construction work, and geotechnical instrumentation monitoring programs.

Mr. Khatari’s extensive foundation and earth structures design experience includes Education B.S., 1994, Civil Engineering, Polytechnic designs of various shallow and deep foundation types using local and international University, Brooklyn, New York design codes and guidelines. He has developed and written contract specification documents for construction and provided construction support services including Licenses & Registrations contractor submittal review and value engineering. Registered Professional Engineer – New York, 093445 Relevant Project Experience POWER GENERATION AND TRANSMISSION Areas of Specialization • Geotechnical Engineering Principal Engineer, Riverhead II Solar – Calverton, Riverhead, New York. This • Foundation Design project involved construction of ground-mounted solar arrays that will be constructed • Construction Observation in a 265-acre site. Responsibility included planning and supervising a geotechnical • Instrumentation and Monitoring exploration that consisted of test borings, infiltration and laboratory testing, and prepared reports presenting results of the exploration with recommendations for foundation design and construction.

Project Manager, Solar Facility, Shoreham, New York. Planned and supervised explorations and foundation studies for ground mounted solar arrays that will be constructed in an approximately 50-acre site. Exploration consisted of test borings, test pits and laboratory testing. A geotechnical report was prepared summarizing our findings and recommendations. Project Manager, Solar Facility, Southold, New York. Planned and supervised explorations and foundation studies for ground mounted solar arrays that will be constructed in an approximately 16-acre site. Exploration consisted of test borings, test pits and laboratory testing. A geotechnical report was prepared summarizing our findings and recommendations. Project Engineer, NEPTUNE Regional Transmission System, Nassau County, New York. Supervised a geotechnical investigation including test borings, cone penetrometer soundings and electrical resistivity testing, and prepared reports presenting results of the investigations with recommendations for foundation design and remediation for the proposed high voltage direct current electrical converter station project. Project Engineer, Cove Point LNG Facility Expansion Project, Dominion Transmission, Lusby, Maryland. This project involved the construction of two 275- foot diameter LNG tanks, 35-foot-wide MSE containment dike around each tank, two turbine generators, administrative buildings, and various support equipment. Responsible for the coordination and execution of a subsurface program consisting of over 50 borings ranging in depth from 40 to 300 feet. Duties include coordination of a

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MHK-PF1 Page 1 of 5 Muktar H. Khatari, P.E. Associate Principal laboratory testing, settlement analysis and foundation recommendations. Prepared geotechnical data report and subsequent pile capacity and settlement analysis for the design team. Project Engineer, Dominion Fairless Hills Energy Center, Fairless Hills, Pennsylvania. Design and construction of two new combined cycle power plants, consisting of a set of gas turbines, a steam turbine/building, above ground cooling lines and cooling tower, water and oil storage tanks and auxiliary equipment. Responsible for the implementation of a ground improvement program that includes the installation of over 20,000 linear feet of Vibro-Replacement Stone Columns and monitoring of dynamic compaction. Duties include pile load testing, and the supervision and monitoring the installation of over 2,200 steel pipe piles. Project Engineer, General Electric Power Systems, TVA Lagoon Creek Energy Plant Phase II, Nutbush, Tennessee. This project involves the addition of 4 turbine generators to an existing power plant. Duties include monitoring pile load testing and the supervision and monitoring of the installation of over 300 augercast concrete piles. Project Engineer, New York Power Authority, In-City Power Generation, Two Large Gas Turbine-Generators, Brooklyn, New York. Coordinated and executed a geotechnical investigation program, including test borings and electrical resistivity tests. Prepared a report presenting results of the investigation with recommendations for foundation design. Project Engineer, Liberty Generating Project, Linden, New Jersey. Supervised subsurface soil investigation for the construction of a 2-mile long underground water pipeline for a proposed 1,100 Mw electric generating plant. Duties include rock coring, collection of undisturbed samples, as well as interacting with various public and private stakeholders regarding access agreements and execution of work plans. INFRASTRUCTURE Project Manager, Willets Point Redevelopment Project, Queens, New York. Coordinated subsurface exploration and provided design and construction recommendations for the infrastructure development of the 40-acre site. The infrastructure development includes a sanitary sewer main (2,400 lf) through a private property (CitiField), two storm sewer outfalls (2,500 lf each) along 126th Street and 127th Street and an existing 72” diameter water main along Willets Point Boulevard. Each of the utility alignments will be supported by piles. Geotechnical challenges unique to the project include deep soft organics, shallow groundwater table, elevated subway, and existing elevated highway. Project Engineer, No. 7 Line Extension Geotechnical and Structural Instrumentation, New York, New York. This project consisted of the instrumentation and monitoring of instrumentation during construction of the No. 7 Line Extension on the west side of the borough of Manhattan in New York City. Instrumentation included inclinometers, piezometers, borehole extensometers, surface monitoring points, tiltmeters and survey prisms. Mr. Khatari managed and coordinated pre and post construction condition survey of different types of structures along the approximately 20 block alignments. Mr. Khatari also coordinated the installation and data collection of the geotechnical instruments, reviewed geotechnical instruments and survey data and advised the client of any ground or structure movements exceeding pre-established limits. Liaising with numerous public agencies was required. Project Engineer, 3rd Avenue Retail Development, BL Companies, Brooklyn, New York. Responsible for executing the vibration and crack gage monitoring of historic building adjacent to proposed retail development site. The site was performing limited excavation work that required the monitoring to meet the requirements of the Housing Preservation and Development. Continued to perform monitoring monthly as required while construction activities continued through completion. Prepared Building Protection Plan for historic building to meet required Landmarks standards. Performed pre-construction building documentation of adjacent buildings and monitored displacement and vibration for landmark structure and two NYCDOT bridges adjacent to the site for 18 months. HOUSING DEVELOPMENT Senior Project Manager, 308 Livingston Street, Brooklyn, New York. Responsible for coordinating the subsurface exploration and soil laboratory testing programs, overseeing the engineering analyses, developing engineering design recommendations,

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MHK-PF1 Page 2 of 5 Muktar H. Khatari, P.E. Associate Principal managing the design and development of support of excavation design drawings for a new 22-story mixed-used development. Design recommendations included micropile and mat slab foundations, below-grade walls, support of excavation and underpinning. Senior Project Manager, 282 West 4th Street, New York, New York. This project involved renovation of an existing three-story multi-family building into a single family residential. The renovation includes a new sub-cellar extending 16 feet below the existing cellar level. Mr. Khatari managed and coordinated this project, which included a subsurface exploration that consisted of test borings and test pits and provided geotechnical recommendation and underpinning design for the proposed renovation. Close coordination with the architect and structural engineer was required to develop foundation recommendations and underpinning design in a dense urban setting. Mr. Khatari also designed and implemented an instrumentation monitoring program that meets the requirements of NYC Building Code and Landmarks Preservation Commission. The monitoring program consisted of pre-construction survey, vibration monitoring, tilt meters, survey prisms and crack monitoring of structures that are within 90 feet of the construction site. Senior Project Manager, 32 Prince Street, New York, New York. This project involved the conversion of a landmark former school building into residential units that included lowering existing cellars by up to 15 feet. Mr. Khatari managed, organized, and executed a subsurface exploration program and provided foundation design recommendations as well as underpinning and support of excavation design for the proposed construction. This project involved close coordination with ownership and the design team. Mr. Khatari also designed and implemented an instrumentation monitoring program that consisted of pre-construction survey, vibration monitoring, crack monitoring and post-construction survey of the surrounding buildings of the proposed construction. Project Manager, 534 West 29th Street, New York, New York. Provided geotechnical consulting services to a developer for foundation design recommendations for a ten-story residential building. The project includes demolition of an existing four-story building and reconstruction into ten stories. Field work included observation of test pits of existing foundations made in the basement and performing three soil borings through the first-floor slab and basement into subgrade utilizing a low overhead electric drill rig. A data report and foundation and geotechnical site construction recommendations were provided. Mr. Khatari also designed an instrumentation monitoring program that consisted of pre-construction survey, vibration monitoring of the surrounding buildings of the proposed construction. Project Manager, Wooster Street, New York, New York. This project involved the construction of a new six-story building in a landmark district. Responsibilities included designating and implementing an instrumentation monitoring program that meets the requirements of NYC Building Code and Landmarks Preservation Commission. The monitoring program consisted of pre- construction survey, vibration and crack monitoring of structures that are within 90 feet of the construction site. Project Manager, 115 King Street, Brooklyn, New York. Provided geotechnical consulting services to a developer, including foundation design recommendations for 2 three-story residential buildings, each having 10 individual townhomes. Field work included performing 10 test borings and providing geotechnical recommendations which included driven pile foundations and alternate drilled pile foundations.

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MHK-PF1 Page 3 of 5 Muktar H. Khatari, P.E. Associate Principal

HOSPITAL/MEDICAL FACILITIES Project Manager, Memorial Sloan Kettering Cancer Center, Laboratory Medical Building, New York, New York. Responsible for the implementation of a geotechnical exploration program, support of excavation design, foundation recommendations, construction monitoring and instrumentation for a nine-story laboratory building in a dense urban setting. The building foundation is at a depth of 50 feet below grade and required excavation of 20 feet of soil and 30 feet of rock. Rock excavation was performed utilizing mechanical means and blasting. Mr. Khatari provided construction specifications for foundations, excavation, and waterproofing, provided construction support services for the below-ground construction work including review of contractor submittals and oversight of field staff providing inspection services for rock excavations within close proximity to adjacent l residential structures. Work included documenting rock anchor tieback installation and testing. Mr. Khatari also designed and implemented an instrumentation monitoring program that consisted of pre and post-construction survey, vibration monitoring, noise and crack monitoring and monitoring deflections/settlements of adjacent structures using Automated Motorized Total Station (AMTS). Project Engineer, Memorial Sloan Kettering Cancer Center, Zuckerman Research Center Phase II, New York, New York. Provided construction support services for the below-ground construction work. Responsible for inspection services for rock excavations within close proximity to adjacent laboratory and residential structures. Work included documenting rock anchor tieback installation and testing, monitoring vibrations with seismographs, monitoring structure deflections using liquid level system, and approval of subgrades for foundations. Project Engineer, Einstein College Medical Center, Bronx, New York. Responsible for the construction oversight of below grade works including driven pipe piles and rock anchors. Work included review of submittals and inspection of construction methods and installation processes. Daily construction activities reports were maintained. Regular communication with the construction manager and owner was made. Project Engineer, Memorial Sloan Kettering Cancer Center, Breast and Imaging Center, New York, New York. Supervised and observed the installation of below-grade works for a new medical facility in midtown New York. Responsible for the review of submittals and inspection of the installation of a caisson foundation system including rock sockets excavated by air-rotary methods, installation of uplift rock anchors, underpinning of neighboring buildings, installation of temporary earth retention system, soil disposal, and subgrade preparation. Accurate records of the daily construction activities including installation logs and daily reports were provided to the construction manager on a daily basis. Installed, maintained, collected, and reported data from tilt meters and seismographs during construction to monitor adjacent properties during construction. Project Engineer, Jacobi Medical Center, The Bronx, New York. Managed geotechnical services, including a soils exploration program for 58 borings into rock and geotechnical report recommending foundation types and details. The project required extensive coordination with the client (Dormitory Authority of the State of New York), hospital facilities management, construction manager, and drilling subcontractor. Project Engineer, St. Frances Hospital, Roslyn, New York. Design and construction of an underground parking garage; duties include supervision of geotechnical investigation, installation of groundwater observation wells, and observation of soil permeability tests. EDUCATIONAL FACILITIES Assistant Project Manager, Satow Stadium, Columbia University, New York, New York. Designed and implemented an investigation program to identify the causes of the settlement problems behind a recently constructed baseball dugout at Satow Stadium. Repair recommendations were provided after the causes of the settlement were identified. Assistant Project Manager, New York Law School, VVA, New York, New York. Responsible for executing a subsurface exploration within the existing subcellar and rear areaway and provide foundation recommendations for the reconstruction of the rear portion of the structure as a result of structure damage caused by settlement during construction at the neighboring site.

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MHK-PF1 Page 4 of 5 Muktar H. Khatari, P.E. Associate Principal

Assistant Project Manager, BMCC Fiterman Hall, New York, New York. Managed a geotechnical drilling program performed for the Dormitory Authority of the State of New York (DASNY). The existing structure was being demolished during the daytime, and the geotechnical work had to be performed during night shifts in the basement of the existing structure after coordinating the work with the General Contractor on a daily basis. The work included soil borings and test pits. Project Engineer, Glen Oaks Campus, Queens, New York. A design/build project for New York City School Construction Authority. Duties included supervision of ground improvement in lieu of removing loose soils and replacing with structural fill, monitoring dynamic compaction program (approx. 150,000 square feet), monitoring vibration during dynamic compaction operations, and performing percolation tests for drywells. COMMERCIAL DEVELOPMENT Assistant Project Manager, World Trade Center Memorial, New York, New York. This project involved the performance of numerous test borings at the World Trade Center site for the proposed memorial. Mr. Khatari coordinated up to four drilling units with inspectors from a different firm and oversaw the borehole logging and testing. Extensive in-situ testing, including pressure meter and packer testing in soil and rock were performed. Assistant Project Manager, Retail Development, Stop & Shop, Brooklyn, New York. Coordination and implementation of a subsurface investigation and laboratory program to evaluate the subsurface conditions. Reported geotechnical findings and provided preliminary deep foundation recommendations to support new grocery store, parking lot and pier head rehabilitation. AVIATION Assistant Project Manager, Delta BHS Screening Facility, Terminal D, LaGuardia Airport, Queens, New York. This project involves the construction of an above-grade extension on the west side of the existing Terminal D building for the BHS Screening Facility. The dimensions of the extension are approximately 35 feet by 140 feet with a footprint area of approximately 4,900 square feet. Provided deep foundation design recommendations, specifications for construction and observation during pile installation. Project Engineer, British Airways, JFK International Airport, New York. Redevelopment of Roadway System including design and construction of various structures; duties included supervision of pile load testing, design of pile foundation, preparation of geotechnical report. Professional Activities Member, American Society of Civil Engineers (ASCE) Treasurer, ASCE Metropolitan Section Geo-Institute Group

Certifications/Training OSHA 29 CFR 1910.120 Training, 1998 8-hour Site Supervisor Certification, 2001 MTA NYCT Track Safety Trained Red Cross, Basic First Aid and CPR

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MHK-PF1 Page 5 of 5

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

MICHAEL W. JUNGHANS, PE

KIMLEY-HORN OF NEW YORK, P.C.

Case No. 17-F-0655 JUNGHANS

1 Q: Please state your name, employer, and business address.

2 A: Michael W. Junghans, PE, Kimley-Horn of New York, P.C., 1 North Lexington Avenue, Suite 1575,

3 White Plains, New York, 10601.

4 Q: What is your position at Kimley-Horn of NY?

5 A: I am a Senior Civil Engineer.

6 Q: How long have you been employed with Kimley-Horn of NY?

7 A: 3 years, I have been employed with KH since March of 2017.

8 Q: Please describe your educational background and professional experience.

9 A: I received a Bachelor of Science in Civil Engineering from The Northeastern University in Boston,

10 Massachusetts and a Masters of Science in Civil Engineering from Rutgers University in New

11 Brunswick, New Jersey. I am a licensed Professional Engineer in New York, New Jersey, Rhode

12 Island, Connecticut, and North Carolina. I have 30 years of experience designing and overseeing

13 private and public site development projects involving large scale grading operations, site layout,

14 utility design, drainage design, site layout, zoning analysis, entitlement permitting and construction

15 support. Additional information on my experience is presented in my curriculum vitae (CV), which is

16 included as Exhibit ____ (MWJ-PF1): Resume of Michael W. Junghans.

17 Q: Please describe your current responsibilities with Kimley-Horn of NY.

18 A: As the Senior Civil Engineer in the northeast I oversee and participate in the development of civil

19 engineering drawings for permitting and construction of site improvements and infrastructure for

20 large scale residential, commercial and industrial projects in the White Plains office. This consists

21 of a wide range of design tasks but of relevance to my testimony in this matter.

22 Q: Have you previously testified before the New York State Public Service Commission or

23 Siting Board on Electric Generation?

24 A: No.

Page 2 of 3

Case No. 17-F-0655 JUNGHANS

1 Q: Have you previously served as an expert witness before any other court, agency, or other

2 body on the subject you plan to offer testimony on today?

3 A: Yes, I have served as an expert witness before Zoning Boards of Appeal, Planning Commissions

4 and Town and Village Boards throughout New York, and New Jersey about civil engineering.

5 Q: What is the purpose and scope of your testimony in this proceeding?

6 A: To sponsor certain portions of the Riverhead Solar 2 Application or the Exhibits thereto.

7 Q: What portion(s) of the Application is your testimony sponsoring?

8 A: Portions of Exhibit 11 and Exhibit 21 related to civil design and storm water management.

9 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

10 direction and supervision.

11 A: Yes.

12 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

13 or documents produced by persons other than yourself/your company? If so, please cite

14 these sources.

15 A: Relevant references, if any, are included in the Exhibits and associated figures and appendices.

16 Q: Does this conclude your testimony?

17 A: Yes.

Page 3 of 3

Michael W. Junghans, P.E. Site Civil Engineer

Michael offers 29 years of experience in the management and performance of land development planning, engineering, and consulting services. He has worked on a wide range of projects for private- and public-sector clients, including the design and development of residential, commercial, retail, and institutional properties as well as data centers, naval facilities, power facilities, and other building types. Professional Sample Experience Credentials

Master of Science, ⚫ Edge-on-Hudson Riverfront Redevelopment, Sleepy Hollow, NY — Civil and Project Manager Environmental ⚫ Sunshine Home Expansion, Ossining, NY — Project Manager Engineering, Rutgers ⚫ Wegmans Food Market, Harrison NY — Project Manager University, 1994 ⚫ Hampshire Country Club Residential Development, Mamaroneck, NY — Project Manager Bachelor of Science, ⚫ Digital Realty Trust Facilities, Various Locations, NJ — Project Manager Civil Engineering, ⚫ Millers Pond Mixed-Use Development, Town of Ramapo, NY —Project Northeastern Manager University, 1989 ⚫ Education First, Tarrytown NY, Esplanade — Project Manager ⚫ Alder Manor - Yonkers, NY — Project Manager Professional Engineer ⚫ Normandy/Toll Brothers, Harrison NY* — Project Manager in Connecticut, New ⚫ Valley Brook Village for Veterans, Bernards Township, NJ* — Project Jersey, Rhode Island, Manager and New York ⚫ The Stop & Shop Supermarket Co., Various Locations* — Project Professional Planner Manager in New Jersey ⚫ CVS Corporation, Various Locations, NJ* — Project Manager ⚫ Boyce Thompson Center - Yonkers, NY* — Project Manager

*Project involvement prior to joining Kimley-Horn

MWJ-PF1 Page1 of 1

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF

PATRICK J. HEATON

ENVIRONMENTAL DESIGN & RESEARCH,

LANDSCAPE ARCHITECTURE, ENGINEERING &

ENVIRONMENTAL SERVICES, D.P.C.

Case No. 17-F-0655 HEATON

1 Q: Please state your name, employer, and business address.

2 A: Patrick J. Heaton, Environmental Design & Research, Landscape Architecture, Engineering &

3 Environmental Services, D.P.C. (EDR), 217 Montgomery Street, Suite 1000, Syracuse, New York

4 13202.

5 Q: What is your position at EDR?

6 A: I am a Principal, Cultural Resources Services.

7 Q: How long have you been employed with EDR?

8 A: I have been employed with EDR since 2010.

9 Q: Please describe your educational background and professional experience.

10 A: I received a Bachelor of Arts degree in Anthropology from Hartwick College in 1994. I received a

11 Master of Arts degree in Anthropology from New York University in 1999. I have over 20 years of

12 experience in performing and/or overseeing cultural resources compliance, environmental

13 permitting, and historic preservation projects. A copy of my resume is submitted as Exhibit ____

14 (PJH-PF1): Resume of Patrick J. Heaton.

15 Q: Please describe your current responsibilities with EDR.

16 A: As the Principal in charge of EDR’s Cultural Resources Division, I oversee all aspects of the firm’s

17 projects related to cultural (i.e., archaeological and historic) resources, as well as managing

18 environmental permitting projects. I am responsible for managing cultural resource surveys and

19 visual impact analyses on behalf of EDR’s clients. I have over 20 years of experience performing

20 and/or supervising projects involving cultural resources, archaeology, environmental impact

21 assessments, visual impact assessments, and historic preservation planning projects.

22 Q: Have you previously testified before the New York State Public Service Commission or Board

23 on Electric Generation Siting and Environmental (“Siting Board”)?

Page 2 of 4

Case No. 17-F-0655 HEATON

1 A: Yes, I previously submitted written testimony to the Siting Board on cultural resources, visual

2 impacts, and/or environmental permitting issues in support of the Article 10 proceedings for the Baron

3 Winds Project (Case No. 15-F-0122) and the Bluestone Wind Energy Facility (Case No. 16-F-0559).

4 In addition, I submitted prefiled testimony in support of the Cassadaga Wind Energy Project (Case

5 No. 14-F-0490), Galloo Island Wind Energy Project (Case No. 15-F-0327), High Bridge Wind Farm

6 (Case No. 18-F-0262), Mohawk Solar Project (Case No. 17-F-0182), Heritage Wind Project (Case

7 No. 16-F-0546), and Flint Mine Solar Project (Case No. 18-F-0087), and in support of Article VII

8 applications for Central Hudson Gas & Electric’s A and C Transmission Line Rebuild Project (Case

9 No. 13-T-0469) and the South Fork Export Cable (Case No. 18-T-0604).

10 Q: Have you previously served as an expert witness before any other court, agency, or other

11 body on the subject you plan to offer testimony on today?

12 A: I have provided testimony before the Public Service Commission of Maryland regarding the review

13 of environmental impacts (including cultural resources and visual impacts) for the Great Bay Solar I

14 Project. In addition, I have provided testimony before the Ohio Power Siting Board regarding the

15 review of environmental impacts (including cultural resources and visual impacts) for the Icebreaker

16 Wind Project.

17 Q: What is the purpose and scope of your testimony in this proceeding?

18 A: To sponsor certain portions of the Riverhead Solar 2 Project Application and the Exhibits thereto.

19 Q: What portion(s) of the Application is your testimony sponsoring?

20 A: Exhibit 20, Cultural Resources and the accompanying Appendices.

21 Q: Were these Exhibits, Application sections, or studies prepared by you or under your direction

22 and supervision.

23 A: Yes.

Page 3 of 4

Case No. 17-F-0655 HEATON

1 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data or

2 documents produced by persons other than yourself/your company? If so, please cite these

3 sources. [These are independent studies, etc.]

4 A: References, if any, are listed in the Exhibits and accompanying Appendices identified above.

5 Q: Does this conclude your testimony?

6 A: Yes.

Page 4 of 4

Patrick J. Heaton, RPA Principal, Cultural Resources Services

Patrick Heaton is a Principal and leads the Cultural Resources Division at EDR. He is a Registered Professional Archaeologist (RPA) with more than 20 years of experience managing cultural resources (i.e., archaeological and historic sites) compliance, environmental permitting, and historic preservation projects, and meets the Qualifications for the Secretary of the Interior’s Standards for Archaeology and Historic Preservation (per 36 CFR 61). His technical expertise includes archaeology, cultural resources management, visual impact assessment, and environmental permitting compliance and strategy, including State Historic Preservation Office (SHPO) and Tribal consultation, Section 106 of the National Historic Preservation Act, the National Environmental Policy Act (NEPA), and the New York State Environmental Quality Review Act (SEQRA). As the Principal in charge of Cultural Resources Services, Patrick oversees cultural resources surveys, archaeological investigations, historic preservation planning projects, and develops avoidance and/or mitigation strategies for archaeological sites and historic properties. Mr. Heaton has significant experience with transportation, energy transmission, and utility-scale renewable energy (wind and solar) projects in New York, New England, Ohio, and Maryland. education employment history Master of Arts, Anthropology, New York University, 1999. Principal, Cultural Resources Services, Environmental Design & Research, Landscape Architecture, Engineering and Environmental Services, D.P.C., Bachelor of Arts, Anthropology, Hartwick College, 1994. Syracuse, NY, 2013-present. registration / certifications Project Manager, Environmental Design & Research, Landscape Architecture, Engineering and Environmental Services, D.P.C., Syracuse, Registered Professional Archaeologist (RPA), 2000. NY, 2010-2013. Meets the Secretary of Interior’s Standards for Archaeology and Historic Associate, Principal Archaeologist, and Project Manager, John Milner Preservation (36 CFR Part 61). Associates, Inc., Croton-on-Hudson, NY, 2004-2010. professional affiliations Project Archaeologist, John Milner Associates, Inc., Croton-on-Hudson, NY, 2000-2004. Board of Directors, Onondaga Historical Association, 2019-present Graduate Teaching Assistant, Anthropology Department, New York Board of Directors, New York Archaeological Council, 2018-present. University, New York, NY, 1997-2000. Member, Council for Northeast Historical Archaeology. Research Consultant, Sass Conservation, Inc., Yonkers, NY, 1998-2000. Member, New York State Archaeological Association (NYSAA). Field Archaeologist, Various Firms, NY, RI, MA, PA, CT, 1995-1999. Vice-President, Board of Directors (2014-2016), Preservation Association of Central New York (PACNY).

Village of Fayetteville Historic Preservation Commission (2010-2014).

Executive Board (2006-2007), Professional Archaeologists of New York City (PANYC). project experience Riverhead 2 Solar Project, Suffolk County, NY- Technical oversight for Phase IA cultural resources survey, Phase IB archaeological survey, State Historic Preservation Office (SHPO) consultation, and Siting Board testimony in support of Article 10 Application to the New York State Board on Electrical Generating Siting and the Environment (NYSPSC Case No. 17-F-0655) for a proposed 36 MW solar energy facility.

Mohawk Solar, Montgomery County, NY- Principal-in-Charge and Project Manager for environmental permitting studies for a proposed 90 MW solar energy facility, the first solar project to pursue a certificate of environmental compatibility and public need under Article 10 of the New York State Public Service Law (NYSPSC Case No. 17-F-0182). Services have included preparation of a Public Involvement Program Plan, Preliminary Scoping Statement, Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

PJH-PF1 Page 1 of 9

Patrick J. Heaton, RPA Principal, Cultural Resources Services

Article 10 Application, GIS data management and mapping, archaeological and historic resources surveys, wetland delineation, threatened and endangered species habitat assessment, avian surveys, agricultural land use analysis, socioeconomic analysis, visual impact assessment, visual mitigation planting plan, public outreach support, stakeholder engagement, agency consultation, and Public Service Commission Siting Board testimony. Sunrise Wind, Visual and Cultural Resources Assessment, Offshore NY/New England- Principal-in-Charge for an historic resources visual effects analysis and visual impact assessment in support of the Constructions and Operations Plan (COP) for a proposed 880-MW offshore wind farm located off the coast of Southern New England. EDR’s services also include an onshore archeological survey, historic resources, survey, and visual resources assessment in support of a New York State Public Service Commission Article VII Application for the onshore interconnection cable route and substation located in Suffolk County (Long Island), New York. As part of a consultant team with Stantec for Orsted, provided technical oversight and QA/QC for technical analyses and reports, consultation with relevant state and federal agencies, and client/team coordination. Flint Mine Solar, Greene County, NY- Principal-in-Charge for environmental permitting studies for proposed 100 MW solar energy facility pursuing a certificate of environmental compatibility and public need under Article 10 of the New York State Public Service Law (NYSPSC Case No. 18-F-0087). Services have included preparation of an environmental permitting Critical Issues Analysis, siting design support, assistance with Public Involvement Program Plan, preparation of a Preliminary Scoping Statement, preparation of the Article 10 Application, Phase IA and IB archaeological investigation, SHPO consultation, wetland delineation, threatened/endangered species habitat assessment, socioeconomic analysis, visual impact assessment, visual mitigation planting plan, public outreach, stakeholder engagement, regulatory agency consultation, and Public Service Commission Siting Board testimony. Bluestone Wind Farm, Broome County, NY- Technical oversight for archaeological survey, historic resources survey and effects analysis, State Historic Preservation Office (SHPO) consultation, cultural resources mitigation, and Siting Board testimony in support of Article 10 Application to the New York State Board on Electrical Generating Siting and the Environment (NYSPSC Case No. 16-F-0559) for a proposed 124 MW wind energy facility. Skipjack Wind Farm, Visual and Historic Resources Assessment, Offshore DE- Principal-in-Charge for an historic resources visual effects analysis and visual impact assessment in support of the Constructions and Operations Plan (COP) for a proposed 120-MW offshore wind farm located off the coast of Delaware and Maryland. As part of a consultant team with Stantec for Orsted, provided technical oversight and QA/QC for technical analyses and reports, consultation with relevant state and federal agencies, and client/team coordination. South Fork Export Cable, On-shore Transmission Line & Substation Facilities, Suffolk County, NY- Principal-in-Charge and Project Manager for State Historic Preservation Office (SHPO) consultation, Phase I archaeological survey, historic-architectural resources survey, and Visual Impact Assessment (VIA) as part of consultant team in support of an New York State Public Service Law Article VII application (NYSPSC Case No. 18-T-0604) for a 138kV underground transmission line and new substation associated with a proposed 90-MW offshore wind energy project. South Fork Wind Farm, Outer Continental Shelf, Rhode Island-Massachusetts Wind Energy Lease Area- Provided technical oversight for historic resources visual effects analysis and terrestrial archaeological assessments in support of National Environmental Policy Act (NEPA) and Section 106 of the National Historic Preservation Act by the Bureau of Ocean Energy Management (BOEM) review for a proposed 90-MW offshore wind energy project. High Bridge Wind Farm, Chenango County, NY- Technical oversight for archaeological survey, historic resources survey and effects analysis, State Historic Preservation Office (SHPO) consultation, cultural resources mitigation, and Siting Board testimony in support of Article 10 Application to the New York State Board on Electrical Generating Siting and the Environment (NYSPSC Case No. 18-F-0262) for a proposed 100 MW wind energy facility. Coxsackie Correctional Facility, Greene County, NY- Principal-in-Charge for a Phase I-III archaeological site investigation and data recovery, wetland delineations, wetland permitting, threatened and endangered species surveys, Incidental Take Permit, and preparation of a habitat conservation plan for a proposed 8-acre Training Facility. Directed archaeological field investigations, artifact analysis, and technical report for a Pre-Contact Native American archaeological site resulting in the recovery of approximately 7,000 artifacts. On behalf of the New York State Department of Corrections and Community Supervision (DOCCS) and Office of General Services (OGS), coordinated agency and stakeholder consultation pursuant to Section 14.09 of the New York State Historic Preservation Act and Section 106 of the National Historic Preservation Act with the New York State Historic Preservation Office, Department of Environmental Conservation, United States Army Corps of Engineers, Stockbridge-Munsee Band of Mohican Indians, and Delaware Nation. Interstate 81 (I-81) Viaduct Project (NYSDOT PIN 3501.60), Archaeological Assessment, City of Syracuse, Onondaga County, NY- Managed the Phase IA Archaeological Sensitivity Assessment and Phase IB shovel testing survey conducted to help support Section 106 of the National Historic Preservation Act consultation and National Environmental Policy Act (NEPA) review as part of a consultant team with Parsons and AKRF, Inc. on behalf of the New York State Department of Transportation (NYSDOT) for the replacement of approximately 5 miles of elevated highways. Coordinated State Historic Preservation Office (SHPO) consultation and assisted with public outreach events/meetings and preparation.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

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Patrick J. Heaton, RPA Principal, Cultural Resources Services

Interstate 81 (I-81) Viaduct Project (NYSDOT PIN 3501.60), Visual Impact Assessment, City of Syracuse, Onondaga County, NY- Managed the Visual Impact Assessment in accordance with Federal Highway Administration (FHWA) standards conducted to help support NEPA review as part of a consultant team with Parsons, AKRF, Inc., and TWMLA for the replacement of approximately 5 miles of elevated highways. Project Icebreaker, Erie County, Cleveland, OH- Technical oversight for historic resources effects analysis conducted in support of Section 106 of the National Historic Preservation Act and National Environmental Policy Act (NEPA) compliance, Certification Application submitted to the Ohio Power Sitting Board (OPSB), and State Historic Preservation Office (SHPO) consultation for a proposed 20 megawatt (MW) offshore wind project Cassadaga Wind Farm, Chautauqua County, NY- Directed the Phase I Archaeological Survey, Historic Resources Survey, State Historic Preservation Office (SHPO) consultation, Visual Impact Assessment, cultural resources mitigation, and Siting Board testimony in support of Article 10 Application to the New York State Board on Electrical Generating Siting and the Environment (NYSPSC Case No. 14-F-0490) for a proposed 70 wind turbine, 126 MW wind energy facility. Baron Winds Project, Steuben County, NY- Directed the Phase I Archaeological Survey, Historic Resources Survey, State Historic Preservation Office (SHPO) consultation in support of Article 10 Application to the New York State Board on Electrical Generating Siting and the Environment (NYSPSC Case No. 15-F-0122) for a proposed (up to) 300 MW wind energy project with up to 80 wind turbines. Hillcrest Solar Project, Brown County, OH- Principal-in-Charge and technical oversight for archaeological and historic resources investigations in support of OPSB Certificate Application and SHPO consultation for a proposed 125 MW solar energy project that will be sited on an approximately 1,400-acre parcel. Timber Road IV Wind Farm and Transmission Line, Paulding County, OH- Technical oversight for archaeological survey, historic resources survey, and cultural resources mitigation plan in support of an OPSB Certificate Application (OPSB Case No. 18-1293-EL-BTX) and SHPO consultation for a proposed 37- turbine, 125-MW wind energy project. Great Bay Solar I, Somerset County, MD- Project Manager for environmental permitting studies in support of Maryland Public Service Commission review for a Certificate of Public Convenience and Necessity (CPCN), including preparation of an Environmental Review Document (ERD), wetland delineations, visual Assessment, Phase I archaeological survey, Phase II archaeological site investigation, historic resources assessment, rare plant survey, wetland permitting, and local permitting for a proposed 100 MW solar energy project located on 800-acres. Church Street Bridge (NYSDOT PIN 1760.55), Washington County, NY – Principal-in-Charge for Section 106 Project Submittal Package, Historic- Architectural Resources Survey, and Phase I Archaeological Survey for a proposed bridge replacement project. Village of Mohawk Water Wells, Herkimer County, NY- Principal-in-Charge for archaeological monitoring of excavation/construction of water wells within a 1.2-acre parcel being redeveloped with storm-resilient municipal and utility infrastructure. Monitoring conducted as part of Section 106 of the National Historic Preservation Act consultation for the New York Governor’s Office of Storm Recovery (GOSR) and Federal Emergency Management Agency (FEMA). City of Oneida Storm Recovery Project, City of Oneida, Madison County, NY- Principal-in-Charge for archaeological investigations, construction monitoring, SWPPP preparation, and SWPPP inspections for demolition of 154 structures in the City of Oneida. Phase I archaeological survey/testing and construction monitoring during construction activities as part of Section 106 of the National Historic Preservation Act compliance for the Federal Emergency Management Agency (FEMA; HMGP Project #4031-0035). Block Island Wind Farm, Block Island, RI- Assisted with management and preparation of VIA for the first offshore wind farm constructed in the United States. Block Island Wind Farm includes 5 wind turbines and is a 30 MW facility located 3 miles off Block Island in the Atlantic Ocean. Project role included field photography, coordination of visual impact analyses, and technical report writing. Master Agreement for Class III Cultural Resources Services, Wyoming Department of Transportation, (2018-2019)- Principal-in-Charge for Master Agreement, numerous Class III inventories statewide in support of transportation infrastructure projects. To date, projects have been completed in Big Horn, Converse, Fremont, Hot Springs, Park, and Washakie Counties under this master agreement. Bates Creek Cultural Resources Inventory Project, Albany, Carbon, Converse, & Natrona Counties, WY (2017)- Principal-in-Charge for Class III Inventory in support of Section 106 compliance for proposed range improvements for the Bureau of Land Management, Casper Field Office. Solar Development Project (Private Client), Worcester County, MD- Oversaw the environmental permitting studies in support of an application for a Certificate of Public Convenience and Necessity (CPCN) from the Maryland Public Service Commission, including preparation of an Environmental Review Document (ERD), wetland delineation and permitting, threatened/endangered species habitat assessment) and cultural (archaeological and historic) resources studies for a proposed 100 MW solar energy project located on 900-acres. Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 3 www.edrdpc.com

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Patrick J. Heaton, RPA Principal, Cultural Resources Services

Walton River Gas Main HDD, Delaware County, NY- Principal-in-Charge for Phase I archaeological survey and Phase II archaeological site investigations for a proposed gas main adjacent to the West Branch of the Delaware River. Beaver Road Industrial Park, Monroe County, NY- Oversaw the Phase IB archaeological investigations for a 49-acre parcel. Onondaga Creekwalk Phase II (NYSDOT PIN 355.14), City of Syracuse, Onondaga County, NY- Managed the environmental permitting services and cultural resources surveys as part of a consultant team with C&S Engineers for the a 2.2-mile recreational trail along Onondaga Creek. Services provided as part of coordinated SEQRA/NEPA review included: preparation of a Section 106 Project Submittal Package; Phase I Archaeological and Historic Resources Surveys; rare, threatened, and endangered (RTE) species assessments; Section 4(f) Consultation correspondence; and, the environmental portions of a NYSDOT Design Approval Document. Term Contract for Bridge Rehabilitation, New York State Thruway Authority (NYSTA), Western New York- Managed the environmental and cultural resources services to support environmental permitting as part of consultant team with Stantec for NYSTA bridge rehabilitation projects. Services include: preparation of Section 106 Project Submittal Packages; Phase IA Archaeological Assessments and/or Phase I Archaeological Surveys; wetland reconnaissance and/or delineations; rare, threatened, and endangered (RTE) species assessments; Section 4(f) Consultation correspondence; and, the environmental portions of Design Approval Documents. Onondaga Lake Parkway/NY Route 370 (NYSDOT PIN 3287.17), City of Syracuse, Onondaga County, NY- Managed environmental permitting studies as part of coordinated SEQRA/NEPA review as part of a consultant team with Lochner for the reconstruction and safety improvements of 2-mile parkway. Services include wetland delineation and permitting, rare, threatened, and endangered (RTE) species assessments, and visual impact assessment.

Arkwright Summit Wind Farm, Chautauqua County, NY- Managed the environmental permitting for a proposed 36-turbine, 78-megawatt (MW) wind energy facility and associated 3-mile generator lead line. Services include managing review under New York State Environmental Quality Review Act (SEQRA), including Lead Agency coordination, preparation of Supplemental Environmental Impact Statement (SEIS), Final Environmental Impact Statement (FEIS), Visual Impact Assessment, shadow flicker analysis, supplemental Phase IB Archaeological Survey, Historic Resources Assessment, and preparation of Joint Application for Permit for wetland permitting for submission to the U.S. Army Corps of Engineers and New York State Department of Environmental Conservation (NYSDEC). North Carolina Wind Energy Lease Areas, NC- Managed the visual assessment conducted as part of a National Environmental Policy Act (NEPA) Environmental Assessment for the North Carolina Wind Energy Area. Commissioned by the Bureau of Ocean Energy Management (BOEM) and ICF, EDR’s visual assessment included identification of visually sensitive sites (e.g., historic sites), field photography, and the production of daytime and nighttime photo simulations demonstrating the potential visibility and visual impact of offshore meteorological towers. This project also included the production of time-lapse videos showing the towers visual impact over an 18-hour period. Emerging Technology & Entrepreneurship Complex (ETEC), University at Albany, Albany County, NY- Oversaw the SEQRA review, including preparation of a Scoping Document, Supplement Environmental Impact Statement (SEIS), Phase IB Archaeological Survey, Visual Assessment, FEIS, SEQRA Findings Statement, and coordination of traffic study (by sub-consultant) on behalf of the State University Construction Fund (SUCF) for a 12-acre site proposed for new academic building on the New York State Office of General Services (OGS) Harriman Campus. Amherst State Park Pedestrian Improvements Project, Town of Amherst, Erie County, NY- Directed the Phase I Archaeological Survey, SHPO consultation, and development of archaeological site avoidance measures for a proposed 1-mile multi-use/pedestrian trail. Seneca Bus Facility, Rochester Genesee Regional Transit Authority (RGRTA), Village of Waterloo, Seneca County, NY- Prepared the Phase I Archaeological Survey and wetland reconnaissance as part of consultant team with AKRF, Inc. in support of NEPA review of 1-acre transit facility. West River Greenway Trail, Grand Island, NY- Oversaw the Phase I Archaeological Survey and visual renderings as part of consultant team with C&S Engineers, Inc. under a Term Services Agreement with the New York State Office of Parks, Recreation, and Historic Preservation (NYSOPRHP) for a proposed 8-mile multi-use/pedestrian trail along the Niagara River. American Packaging Facility, Town of Chili, Monroe County, NY- Prepared the Phase I Archaeological Survey and SHPO consultation for a proposed 35-acre commercial/light industrial facility.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 4 www.edrdpc.com

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Patrick J. Heaton, RPA Principal, Cultural Resources Services

Interstate 690 (I-690) Teall Avenue & Beech Street Interchange (NYSDOT PIN 3501.60), City of Syracuse, Onondaga County, NY- Oversaw the Visual Assessment and Archaeological Resources Screening for National Environmental Protection Act (NEPA) and Section 106 consultation as part of a consultant team with Parsons and AKRF, Inc. on behalf of the NYSDOT for a bridge replacement and intersection improvement of 0.5-mile elevated highway. Canalways Trail (NYSDOT PIN 3950.49), City of Syracuse, Onondaga County, NY- Directed the Section 106 Project Submittal Package and Phase IA Archaeological Assessment as part of a consultant team with CHA for the design and construction of a 2.7-mile recreational trail along the shoreline of Onondaga Lake. Penn Forest Wind Farm, Carbon County, PA- Supervised the preliminary visual assessment, visual fieldwork, viewshed analysis, visual simulations, and preparation of public outreach materials for proposed 40-turbine wind energy facility. Stiles Brook Wind Farm, Towns of Windham and Grafton, VT- Oversaw the preliminary visual assessment, visual fieldwork, viewshed analysis, visual simulations, and preparation of public outreach materials for proposed 30-turbine wind energy facility. Substation Relocation, Village of Mohawk, Herkimer County, NY- Managed the Phase I Archaeological Survey conducted as part of Section 106 of the National Historic Preservation Act consultation for a proposed 1.2-acre substation relocation project. Project sponsored by New York Governor’s Office of Storm Recovery (GOSR) and Federal Emergency Management Agency (FEMA). Highway Garage, Town of Nichols, Tioga County, NY- Supervised the Phase I Archaeological Survey conducted as part of Section 106 of the National Historic Preservation Act consultation for a 7.0-acre site proposed for relocation of a municipal highway garage. Project sponsored by New York Governor’s Office of Storm Recovery (GOSR) and U.S. Department of Housing and Urban Development (HUD).

Jericho Rise Wind Farm, Franklin County, NY- Directed the Phase IB archaeological survey, historic resources survey and effects analysis, and SHPO consultation in support of SEQRA review and U.S. Army Corps of Engineers wetland permitting for a proposed 37 wind turbine, 78 MW wind energy facility. Liverpool Village Cemetery Restoration Plan, Village of Liverpool, Onondaga County, NY- Oversaw the historic landscape preservation planning and restoration project, associated NYS Consolidated Funding Application (CFA), and public outreach for a 6-acre cemetery listed on the National Register of Historic Places (NRHP). Cumberland Bay State Park, Camping Area Comfort Station Replacements, Clinton County, NY- Principal-in-Charge and Project Manager for a Phase I Archaeological Survey for proposed comfort station replacements in a state park on Lake Champlain. Services provided as part of a consultant team with Beardsley Architects & Engineers, D.P.C. under a Term Services Agreement with the New York State Office of Parks, Recreation, and Historic Preservation (NYSOPRHP). Montezuma Heritage Park & Giardina Park, Town of Montezuma, Cayuga County, NY- Supervised the Phase IA Archaeological Resources Surveys in support of historic preservation planning for a proposed 168-acre heritage park that interprets archaeological remains of the Erie and Cayuga-Seneca Canals and an additional 16-acre town park. Main Street Campus Improvements, Rochester Genesee Regional Transit Authority (RGRTA), City of Rochester, Monroe County, NY- Prepared a Phase IB Archaeological Survey in support of NEPA review of this 3-acre transit facility. School of Pharmacy, Binghamton University, Village of Johnson City, Broome County, NY- Supervised the SEQRA review (including preparation of a Full Environmental Assessment Form, or EAF) and Phase IA Archaeological Assessment on behalf of the State University Construction Fund (SUCF) for a 5.5-acre site proposed for new academic building. Maxwell Field Streambank Stabilization Project, City of Oneida, Madison County, NY- Prepared the Phase I Archaeological Survey for this 0.3-acre streambank stabilization project. Chain Works District Redevelopment Project, City of Ithaca, Tompkins County, NY- Prepared a Phase IA Archaeological Survey in support of SEQRA review of 95-acre historic industrial site proposed for redevelopment. Central Hudson Gas & Electric W-H & G Transmission Lines, Ulster County & Dutchess County, NY- Directed the SHPO consultation, Phase I archaeological surveys, and visual impact studies in support of NYS Public Service Commission Part 102 Applications for the refurbishment of a 13-mile transmission-line and an 11-mile transmission line.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 5 www.edrdpc.com

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Patrick J. Heaton, RPA Principal, Cultural Resources Services

Coye Hill Wind Farm, Tolland County, CT- Supervised the Natural Resources Impact Evaluation Report and consultation with the Connecticut SHPO in support of Petition for a Declaratory Ruling from the Connecticut Siting Council for proposed 4-turbine, 12 MW wind energy project. NFG Dunkirk Pipeline, Chautauqua County, NY- Supervised the SHPO consultation and Phase I Archaeological Surveys in support of NYS Public Service Commission Article VII Application for a proposed 9-mile natural gas pipeline. Orleans County Transit Facility, Rochester Genesee Regional Transit Authority (RGRTA), Orleans County, NY- Prepared the Phase IA Archaeological Survey in support of NEPA review of proposed 2-acre bus storage/service facility. Great Bay Wind Project, Somerset County, MD- Prepared the cultural resources surveys, the consultation with the Maryland Historical Trust (MHT), and the Visual Impact Assessment for a proposed 35-turbine, 100 MW wind energy project. Services provided in support of Maryland Public Service Commission review for a CPCN and Section 106 consultation as part of NEPA review by the U.S. Fish and Wildlife Service in association with Bald and Golden Eagle Protection Act take permit review. Onondaga Lake West Revitalization Area, Village of Solvay, Onondaga County, NY- Prepared a Phase IA cultural resources surveys of 400-acre brownfield area and proposed streetscape improvements. National Grid Van Dyke Road Substation, Albany County, NY- Directed the Visual Impact Assessment and Phase I archaeological survey for a proposed 4.3-acre substation site and 1.6-mile underground transmission duct bank. Batavia Senior Housing Project, Genesee County, NY- Supervised the Phase I Archaeological Survey and prepared Phase II Archaeological Site Investigation Work Plan/Research Design for a 13.5-acre site proposed for development as a senior housing facility.

Copenhagen Wind Project, Lewis County, NY- Prepared the Phase I Archaeological Survey and Historic Resources Survey, New York SHPO consultation, Visual Impact Assessment, and prepared sections of Draft Environmental Impact Statement (DEIS) and FEIS as part of SEQRA review for proposed 47-turbine, approximately 79 MW wind energy project. Black Oak Wind Farm, Tompkins County, NY- Directed the Phase IA Cultural Resources Survey, Historic Resources Visual Effects Analysis, and SHPO consultation in support of SEQRA review for a proposed 7-wind turbine, 14-MW wind energy project. Downtown Syracuse Commercial Historic District, City of Syracuse, Onondaga County, NY- Prepared the National Register of Historic Places (NRHP) nomination and Multiple Property Documentation Form on behalf of the Downtown Committee of Syracuse, Inc. for a proposed 21-acre historic district. The nomination was approved by the National Park Service and listed on the NRHP on May 7, 2013. Chittenango Landing Dry Dock Complex Cultural Landscape Report, Town of Sullivan, Madison County, NY- Prepared the Part 1 of a Cultural Landscape Report (CLR) on behalf of the Chittenango Landing Canal Boat Museum for a 6-acre historic site/museum listed on the NRHP. The interpretive site includes a 19th-century dry dock complex and associated buildings located on the Erie Canal. National Grid Aquidneck Island Reliability Project, Newport, RI- Directed visual fieldwork, visual simulations, and report preparation for a Visual Impact Assessment (VIA) for the proposed upgrade of approximately 4.4 miles of National Grid 69 kV transmission line to 115 kV. Mary Cariola Children’s Center, Town of Henrietta, Monroe County, NY- Supervised a Phase I Archaeological Survey conducted as part of SEQRA review for a proposed residential facility for disabled children located on 1.3-acres. Central Hudson Gas & Electric A & C Transmission Lines, Dutchess County, NY- Directed SHPO consultation, Phase I Archaeological Survey, and Visual Impact Assessment in support of Article VII application (NYSPSC Case No. 13-T-0469) for the rebuild of 11 miles of 115 kV transmission lines. Indian Point Energy Center (IPEC), Westchester County, NY- On behalf of Scenic Hudson, Inc., and Riverkeeper, coordinated preparation of visual simulations and Visual Impact Assessment for a proposed closed-cycle cooling (CCC) system at a nuclear energy facility. Scioto Ridge Wind Farm, Hardin & Logan Counties, OH- Prepared Cultural Resources Survey Work Plans in support of Ohio Power Siting Board (OPSB) Certificate Application for proposed wind energy project with up to 176 wind turbines and a generating capacity of up to 300 MW.

School of Medical & Biological Sciences, University at Buffalo, City of Buffalo, Erie County, NY- Supervised the SEQRA process on behalf of the State University Construction Fund, including preparation of DEIS and support studies (Visual Assessment, Archaeological Sensitivity Assessment, and

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 6 www.edrdpc.com

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Patrick J. Heaton, RPA Principal, Cultural Resources Services

Historic Resources Impact Assessment), conducted SEQRA public hearing, preparation of FEIS, and SEQRA Findings Statement for a proposed ~600,000 gross square foot medical/educational facility located on the University at Buffalo’s Downtown Campus. Wild Meadows Wind Project, Grafton & Merrimack Counties, NH- Directed visual fieldwork/photography and presented visual resources analyses and simulations at public open houses conducted in support of Section 106 of the National Historic Preservation Act (NHPA) consultation for a proposed 37- turbine, 74 MW wind energy project. Loveless Farms, Town of Skaneateles in Onondaga County, NY- Directed the Phase I Archaeological Survey and Visual Impact Assessment in support of SEQRA review for a proposed 18-lot subdivision located on 47-acres. White Pine Commerce Park, Town of Clay, Onondaga County, NY- Supervised the Phase I Archaeological Survey and SHPO consultation for Onondaga County Industrial Development Authority (OCIDA) in support of SEQRA review for a 300-acre parcel and 4-mile sewer line. Empire Brewing Company Farmstead Brewery, Town of Cazenovia, Madison County, NY- Oversaw the visual assessment, viewshed analyses, visual simulations, and analysis of visual effects on NRHP-listed properties as part of SEQRA review for a proposed craft brewery. Wilcox Estates, Town of Barton in Tioga County, NY- Oversaw the Phase I Archaeological Survey as part of SEQRA review for a proposed 32-lot subdivision located on 20-acres. Barcelona Water Improvement District, Town of Westfield in Chautauqua County, NY- Prepared the Phase I Archaeological Survey as part of Section 106 of the NHPA review for a 4-mile long public water system located in the hamlet of Barcelona. Village of Danforth Historic Resources Survey, Syracuse, Onondaga County, NY- Developed the public outreach strategy, historic resource inventory forms, and visual field guide to enable community volunteers to conduct a Neighborhood Historic Resource Survey and NRHP eligibility evaluation of over 300 buildings for the City of Syracuse Bureau of Planning and Sustainability. Student Life Center, SUNY Cortland, City of Cortland, Cortland County, NY- Supervised the SEQRA process on behalf of the State University Construction Fund, including preparation of DEIS, support studies (including, Visual Impact Assessment, Phase IA Cultural Resources Survey, and Phase 1 Environmental Site Assessment), FEIS and SEQRA Findings Statement for proposed recreational athletic facility. Newfield Covered Bridge (NYSDOT PIN 37550), Town of Newfield, Tompkins County, NY- Prepared the Phase IA Cultural Resources Survey for a NRHP-listed historic bridge rehabilitation. Owasco River Greenway Trail (NYSDOT Project 375557), City of Auburn & Town of Fleming, Cayuga County, NY- Directed the Phase IA Cultural Resources Survey for a proposed 8.4-mile-multi-modal recreational trail. Niagara Falls Underground Railroad Heritage Area Management Plan, Niagara County, NY- Prepared a Heritage Area Management Plan (HAMP) authorized under Section 35.05 of the New York State Parks, Recreation, and Historic Preservation Law to identify and encourage heritage tourism opportunities related to the Underground Railroad in the Niagara Falls vicinity. American Society of Landscape Architects (ASLA) Upstate Chapter Award for Historic Preservation. Seneca Park Zoo Parking Lot Expansion, City of Rochester & Town of Irondequoit, Monroe County, NY- Managed a Phase I Archaeological Survey in support of SEQRA review on behalf of Monroe County Parks Department for a 1.5-acre parcel. Crown City Wind Project, Cortland County, NY- Managed the Cultural Resources Survey, Visual Impact Assessment, and prepared DEIS sections as part of SEQRA review for proposed 44-turbine, approximately 71 MW wind energy project. Buckeye II Wind Project, Champaign County, OH- Directed the Visual Impact Assessment for a proposed 56-turbine, 140 MW wind energy project in support of an Application for a Certificate of Environmental Compatibility and Public Need to the Ohio Power Siting Board (OPSB). Monticello Hills Wind Project, Otsego County, NY- Supervised the SEQRA process and preparation of permitting support studies (including Full Environmental Assessment Form, Visual Impact Assessment, wetland delineation, shadow-flicker analysis, Phase IA Cultural Resources Survey, Historic Resources Survey, and Phase IB Archaeological Survey) for a proposed six-turbine, 18 MW wind energy project.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 7 www.edrdpc.com

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Patrick J. Heaton, RPA Principal, Cultural Resources Services

South Mountain Wind Project, Delaware County, NY- Managed the preparation of environmental permitting studies in support of SEQRA review (including wetland delineation, threatened and endangered species habitat assessment, and timber rattlesnake survey) for a proposed community-scale wind energy project. Smokey Avenue Wind Project, Otsego County, NY- Supervised the preparation of environmental permitting studies in support of SEQRA review (including Shadow Flicker Analysis, ballooning fieldwork and visibility study, and Phase IA Cultural Resources Survey) for proposed community-scale wind energy project. Roaring Brook Wind Power Project, Lewis County, NY- Directed the supplemental/addendum Phase IB Archaeological Survey in association with project layout revisions for a proposed 79MW wind energy project. Sackets Harbor Battlefield National Historic Landmark (NHL) Nomination, Jefferson County, NY- Prepared sections of NHL nomination and Battlefield Preservation Plan for the 260-acre War of 1812 battlefield in Sackets Harbor, under a grant from the American Battlefield Protection Program of the National Park Service. Warren Hull Family Home & Farmstead, Erie County, NY- Coordinated preparation of graphic displays for cultural landscape historic overview and treatment plan to support restoration of the landscape at a ca. 1825 landmark house museum. Long Island - New York City Offshore Wind Project, Queens, Nassau, & Suffolk Counties, NY- Supervised the preparation of visual simulations, web- based presentation, and associated visualization services for a proposed 350 MW offshore wind energy project located in the Atlantic Ocean approximately 13-miles off the coast.

Allegany Wind Power Project, Cattaraugus County, NY- Prepared the supplemental/addendum Phase IB Archaeological Survey in association with review of construction plans by New York SHPO for a proposed 29-turbine, 72.5 MW wind energy project. Horse Creek Wind Farm, Jefferson County, NY- Directed the Visual Impact Assessment, including viewshed analysis, field work, photographic simulations, and VIA report for a proposed 50-turbine, 100 MW wind energy project. Tioga Downs Wastewater Improvement Project, Tioga County, NY- Supervised the Phase I Archaeological Survey and Phase 2 Archaeological Site Investigation of a pre-contact Native American archaeological site for a wastewater treatment facility and 0.5-mile water line. Collegetown Terrace, Tompkins County, NY- Managed the SEQRA review and prepared FEIS on behalf of the City of Ithaca Planning & Development Board for a 16-acre, 1,260-unit student housing project. Big Savage 138 kV Generator Lead, Allegany County, MD- Managed the Visual Impact Assessment and Cultural Resources Assessment for Maryland Public Service Commission CPCN review of a proposed 7-mile transmission line. Marble River Wind Project, Clinton County, NY- Supervised the cultural resources and visual impacts analyses for SEQRA permitting review of a revised layout for a 74-wind turbine, 222 MW wind energy project. Amherst State Park Veterans Memorial, Erie County, NY- Managed the Phase IB Archaeological Survey for a proposed veterans’ memorial and 1,500- foot footpath in Amherst State Park. Timber Road II Wind Project, Paulding County, OH- Directed the Visual Impact Assessment for a 109-turbine, 150 MW wind energy project in support of an Application for a Certificate of Environmental Compatibility and Public Need submitted to the Ohio Power Siting Board (OPSB). Hardscrabble Wind Power Project, Herkimer County, NY- Directed the supplemental Phase IB Archaeological Survey, construction monitoring, and compliance with U.S. Army Corps of Engineers/SHPO Memorandum of Agreement for a 37-turbine, 74 MW wind energy project. Benson Mines Meteorological Tower, St. Lawrence County, NY- Directed the visual assessment, ballooning fieldwork, and visual simulations in accordance with the Adirondack Park Agency (APA) Visual Analysis Methodology for a proposed 160-foot meteorological tower. Deerfield Wind Power Project, Bennington County, VT- Prepared sections of Supplemental DEIS for a 15-turbine, 30 MW wind energy project located in the Green Mountain National Forest, as part of NEPA review on behalf of the U.S. Department of Agriculture (USDA) National Forest Service. National Grid 115 kV Line, Lighthouse Hill to Coffeen Street, Oswego & Jefferson Counties, NY- Prepared visual impact assessment portion of Part 102 Report for a 40-mile 115 kV transmission line maintenance and refurbishment project. Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 8 www.edrdpc.com

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Patrick J. Heaton, RPA Principal, Cultural Resources Services

National Grid Eastover Road Substation & Tap Line, Town of Schagticoke, Rensselaer County, NY- Ballooning/visual impact assessment fieldwork for a proposed 6.4-acre 230/115 kV substation and 0.75-mile 155 kV tap line. publications/presentations

Panel Discussion Participant. Native American Consultation Practices. 2019 Spring Meeting, New York Archaeological Council (NYAC). April, 2019. Presenter. It’s a Brave New World: Online Consultation with the New York State Historic Preservation Office (SHPO). 2015 New York State Wetlands Forum Conference, Syracuse, NY. April 2015. Poster Presentation. The Effect of Larger Rotor Diameters and Taller Hub Heights on Shadow Flicker Impacts. 2013 American Wind Energy Association (AWEA) Wind Conference, Chicago, IL. May 2013.

Presenter. Cultural Heritage Planning: History as a Marketable Asset. Annual Conference of the New York Upstate Chapter of the American Planning Association, Corning, NY. September 2012. Presenter. Use of Visualization Techniques and Computer Graphics to Address the Visibility and Appearance of Offshore Wind Projects. 2011 AWEA Offshore Wind Conference, Baltimore, MD. October 2011. Heaton, Patrick J., J. Sanderson Stevens, L.E. Branch-Raymer, & J. Wettstaed. 2010. Archaeological Investigations of an Early Farmstead Site in Shelby County, Indiana. Indiana Archaeology 5(2):74-95.

Heaton, Patrick J. 2003. The Rural Settlement History of the Hector Backbone. Northeast Historical Archaeology 32:19–28. Heaton, Patrick J. 2003. Farmsteads and Finances in the Finger Lakes: Using Archival Sources in a GIS Database. Northeast Historical Archaeology 32:29–44. Six, Janet, Patrick J. Heaton, Susan Malin-Boyce, & James A. Delle. 2003. The Artifact Assemblage from the Finger Lakes National Forest Archaeology Project. Northeast Historical Archaeology 32:79–94. Delle, James A., & Patrick J. Heaton. 2003. The Hector Backbone: A Quiescent Landscape of Conflict. Historical Archaeology 37(3):93-110. Heaton, Patrick J. 2000. Book review of Nineteenth- and Early Twentieth-Century Domestic Site Archaeology in New York State, edited by John P. Hart and Charles L. Fisher, New York State Museum Bulletin No. 495, Albany, NY, 2000. Published in Northeast Anthropology 60:93-94.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 9 www.edrdpc.com

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NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

SAMANTHA VANETTI-RECORE

ENVIRONMENTAL DESIGN & RESEARCH,

LANDSCAPE ARCHITECTURE, ENGINEERING &

ENVIRONMENTAL SERVICES, D.P.C.

Case No. 17-F-0655 VANETTI-RECORE

1 Q: Please state your name, employer, and business address.

2 A: Samantha Vanetti-Recore, Environmental Design & Research, Landscape Architecture,

3 Engineering and Environmental Services, D.P.C. (“EDR”), 217 Montgomery Street, Syracuse, New

4 York 13202.

5 Q: What is your position at EDR?

6 A: Project Manager.

7 Q: How long have you been employed with EDR?

8 A: I have been employed with EDR since 2017.

9 Q: Please describe your educational background and professional experience.

10 A: I received a Bachelor of Science in Environmental Biology from the State University of New York

11 College of Environmental Science & Forestry in 2010. I also received a Master of Environmental Law

12 & Policy from Vermont Law School in 2012. I have over 8 years of experience in environmental law

13 and policy, environmental permitting, floodplain management and federal grant compliance and

14 administration. My current curriculum vitae is attached and provides a full history of my relevant

15 professional experience. A copy of my resume is submitted as Exhibit ____ (SVR-PF1).

16 Q: Please describe your current responsibilities with EDR.

17 A: In my current position, I am responsible for interfacing directly with clients, project legal counsel,

18 team partners, sub-consultants, and regulatory personnel in support of environmental permitting

19 efforts with a specific focus on Article 10 of the New York Public Service Law for the siting of

20 renewable energy projects.

21 Q: Have you previously testified before the New York State Public Service Commission or

22 Siting Board on Electric Generation?

23 A: Yes, I have provided pre-filed testimony in the Mohawk Solar Proceeding (Case No. 17-F-0182).

Page 2 of 3

Case No. 17-F-0655 VANETTI-RECORE

1 Q: Have you previously served as an expert witness before any other court, agency, or other

2 body on the subject you plan to offer testimony on today?

3 A: No.

4 Q: What is the purpose and scope of your testimony in this proceeding?

5 A: To sponsor certain portions of the Riverhead Solar 2 Project Application or the Exhibits thereto.

6 Q: What portion(s) of the Application is your testimony sponsoring or co-sponsoring?

7 A: Exhibit 2: General Requirements, Exhibit 3: Location of Facilities, Exhibit 9: Alternatives, Exhibit 10:

8 Consistency with Energy Planning Objectives, Exhibit 17: Air Emissions, Exhibit 23: Water

9 Resources and Aquatic Ecology, Exhibit 28: Environmental Justice, Exhibit 31: Local Laws and

10 Ordinances, Exhibit 32: State Laws and Regulations, Exhibit 33: Other Applications and Filings

11 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

12 direction and supervision.

13 A: Yes.

14 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

15 or documents produced by persons other than yourself/your company? If so, please cite

16 these sources.

17 A: References, if any, are listed in the Exhibits and accompanying Appendices identified above.

18 Q: Does this conclude your testimony?

19 A: Yes.

Page 3 of 3

Samantha Vanetti-Recore Project Manager

Samantha is a Project Manager at EDR with over 8 years of professional experience. Samantha previously worked in Vermont and New York City managing climate change and flood resiliency projects. She has a strong background in environmental law and policy, environmental permitting, floodplain management and federal grant compliance and administation. Samantha graduated with a Masters of Environmental Law & Policy from Vermont Law School and a Bachelor of Science from the State University of New York College of Environmental Science & Forestry. As a Project Manager with EDR, Samantha interfaces directly with clients, project legal counsel, team partners, sub-consultants, and regulatory personnel in support of environmental permitting efforts, with a specific emphasis on Article 10 of the New York Public Service Law. Samantha is also responsible for conducting environmental review, impact analysis, and permitting; coordinating internal project staff and external team members to prepare deliverables and meet project deadlines; quality assurance/quality control of regulatory permitting studies and exhibits; and, supporting public outreach efforts for both renewable energy and flood resiliency projects. education employment history Master of Environmental Law & Policy, Vermont Law School, 2012. Senior Environmental Analyst, Environmental Design & Research, Landscape Architecture, Engineering & Environmental Services, DPC, Bachelor of Science, Environmental Biology, State University of New York Syracuse, NY, 2017-2019. College of Environmental Science & Forestry, 2010. Senior Project Manager, New York City Department of Housing registration / certifications Preservation & Development, New York, New York, 2016-2017. Certified Floodplain Manager (CFM) Project Manager, New York City Department of Housing Preservation & Development, New York, New York, 2015-2016. professional affiliations Planner, Two Rivers-Ottauquechee Regional Commission: Woodstock, Member, Association of State Floodplain Managers (ASFPM) Vermont, 2012-2015. Former Member, Vermont Law School Alumni Association Board of Legal Intern, Conservation Law Foundation, Montpelier, Vermont, 2012. Directors Former Commissioner & Secretary of the Executive Committee, Connecticut River Joint Commissions project experience

Mohawk Solar, Montgomery County, NY- As the project manager, responsible for coordinating environmental permitting studies for a proposed 90 MW solar energy facility, the first solar project to pursue a certificate of environmental compatibility and public need under Article 10 of the New York State Public Service Law. Project responsibilities included management, preparation, coordination, and quality control review of permitting support studies and Article 10 Application exhibits, including coordination with client/consultant team, internal staff, and subconsultants. Riverhead Solar 2, Suffolk County, NY- As the project manager, responsible for the management, preparation, coordination, and quality control review of a Public Involvement Program Plan, Preliminary Scoping Statement and Application in support of Article 10 permitting for a 36 MW solar energy generating project. Onondaga Creek Bank Stabilization Project, Onondaga County, NY- As the project manager, prepared the State Environmental Quality Review (SEQR) documents and coordinated with state and federal agencies for a bank stabilization project associated with the Onondaga Creekwalk in downtown Syracuse, New York.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

Samantha Vanetti-Recore Project Manager

Baron Wind Project, Steuben County, NY- Responsible for the preparation and coordination of an Article 10 Application, Application Supplements, and an Application Update for a wind energy project. In coordination with project legal counsel, developed and submitted responses to Interrogatory Requests (IRs), and participated in meetings and conferences. Bluestone Wind Project, Broome County, NY- Responsible for the preparation and coordination of permitting support studies, an Article 10 Application, and Application Supplement for an approximately 40-turbine commercial wind power project. Heritage Wind Project, Orleans County, NY – Responsible for the preparation, coordination and quality control review of a Preliminary Scoping Statement in support of Article 10 permitting. Ogdensburg Shoreline Erosion Management Study, Ogdensburg, NY— Technical expert for flood resiliency planning project, funded by a Sea Grant from the National Oceanic and Atmospheric Administration (NOAA) on behalf of the City of Ogdensburg. Assessed riverine flooding risk of select public assets and developed targeted resiliency and mitigation strategies while taking into consideration local impacts of climate change and river geomorphology. Onondaga County Hazard Mitigation Plan, Onondaga County, NY- Assisted with updating the 2012 Multi- Jurisdictional Hazard Mitigation Plan that involved collaboration with Onondaga County and all 37 municipalities within the county. Aided on summary review of all local, county, and regional plans and ordinances relevant to hazard mitigation to update the capability assessment section of the 2013 Onondaga County Multi-Jurisdictional Hazard Mitigation Plan. experience prior to joining EDR Senior Project Manager, New York City Department of Housing Preservation & Development—Managed and coordinated with the subconsultant preparing the NEPA Tier II environmental review for projects in the Build-it-Back Multifamily Program’s pipeline. This Program was developed to assist the owners of multifamily buildings affected by Hurricane Sandy within the five boroughs of New York City and was funded by the U.S. Department of Housing and Urban Development’s (HUD) Community Development Block Grant- Disaster Recovery (CDBG-DR) grants. Planner, Two Rivers-Ottauquechee Regional Commission – Project managed and conducted the environmental review for public infrastructure projects damaged by Tropical Storm Irene. These projects were funded by HUD CDBG-DR grants.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

STATE OF NEW YORK PUBLIC SERVICE COMMISSION ______

PRE-FILED TESTIMONY OF:

SAMUEL GORDON

SENIOR PROJECT MANAGER

ENVIRONMENTAL DESIGN & RESEARCH,

LANDSCAPE ARCHITECTURE, ENGINEERING &

ENVIRONMENTAL SERVICES, D.P.C.

Case No. 17-F-0655 GORDON

1 Q: Please state your name, employer, and business address.

2 A: Samuel Gordon, Environmental Design & Research, Landscape Architecture, Engineering &

3 Environmental Services, D.P.C. (EDR), 217 Montgomery Street, Suite 1000, Syracuse, New York

4 13202.

5 Q: What is your position at EDR?

6 A: Senior Project Manager

7 Q: How long have you been employed with EDR?

8 A: I have been employed at EDR since 2019.

9 Q: Please describe your educational background and professional experience.

10 A: I received a Bachelor of Science in Environmental Policy and Management (1997), a Master of

11 Professional Studies in Environmental and Community Land Use Planning (2001), and a Master of

12 Landscape Architecture from the State University of New York College of Environmental Science

13 and Forestry (2005). I was the Director of Planning and Zoning for the Town of DeWitt (just east of

14 the City of Syracuse, NY) from 2014 until 2019, where I oversaw the implementation of the Town’s

15 Comprehensive Plan, wrote and managed grants on behalf of the Town, coordinated the Town site

16 plan review process, and oversaw targeted planning initiatives. Since joining EDR, I have managed

17 a variety of projects as a land use and community planning professional, including: researching and

18 drafting waterfront revitalization plans, developing targeted neighborhood reinvestment plans,

19 comprehensive plans, and other local plans and reports; and have coordinated outreach meetings

20 and events; and grant writing. Recently I have assisted with the preparation of land use exhibits and

21 visual impact assessments for large scale solar projects. A copy of my resume is submitted at Exhibit

22 ____ (SG-PF1): Resume of Samuel Gordon.

23 Q: Please describe your current responsibilities with EDR. Case No. 17-F-0655 GORDON

24 A: As a Senior Project Manager at EDR, I am responsible for project coordination, technical research,

25 and drafting reports and meeting materials relating to land use and community planning projects,

26 including local waterfront revitalization plans, comprehensive plans, zoning reviews, and targeted

27 neighborhood investment plans. In addition, I coordinate and lead project-related community

28 outreach meetings and events and manage the development of outreach materials. I am also

29 responsible for the development of land use and visual impact analyses associated with utility-

30 scale solar energy projects and preparing the exhibits and reports to be submitted with the

31 applications to the state.

32 Q: Have you previously testified before the New York State Public Service Commission or

33 Siting Board on Electric Generation?

34 A: No.

35 Q: Have you previously served as an expert witness before any other court, agency, or other

36 body on the subject you plan to offer testimony on today?

37 A: No.

38 Q: What is the purpose and scope of your testimony in this proceeding?

39 A: To sponsor certain portions of the Riverhead Solar 2 Project Application or the Exhibits thereto.

40 Q: What portion(s) of the Application is your testimony sponsoring?

41 A: Exhibit 4, Land Use

42 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

43 direction and supervision.

44 A: Yes.

45 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

46 or documents produced by persons other than yourself/your company? If so, please cite

47 these sources. [These are independent studies, etc.] Case No. 17-F-0655 GORDON

48 A: See Exhibit 4 for any references.

49 Q: Does this conclude your testimony?

50 A: Yes.

Samuel Gordon Senior Project Manager

Sam is a Senior Project Manager for EDR. Sam has over 20 years of experience in the Planning and Sustainability fields with a diverse background including neighborhood revitalization, greenway planning, sustainability planning, and mobility planning; and has worked in both the public and private sector; as well as internationally. Sam has managed and/or provided consulting expertise on a variety of projects from greenway planning, energy conservation and renewable energy deployment, to neighborhood revitalization and alternative mobility projects. Sam received a Fellowship in 2005 to work with the Center for Environmental Studies in Vitoria-Gasteiz, Spain, which was selected as the European Green Capital for 2012.

As a Project Manager with EDR, Sam is the principal point of client and public interaction on many projects, responsible for staff resourcing and scheduling, financial management, and quality assurance for project deliverables. He is also frequently a lead producer of technical research and writing for planning reports and documents including comprehensive plans, feasibility studies, grant applications, compliance documents, and similar deliverables. Sam typically oversees project-related community outreach meetings/events and the development of outreach materials; plans and facilitates project meetings; and guides the production of written and graphic materials for public distribution. education employment history Director of Planning and Zoning, Town of DeWitt, NY 2014- 2019. Master of Landscape Architecture, SUNY ESF, Syracuse, NY, 2005. Senior Planner, Central New York Regional Planning and Development Master of Professional Studies, Environmental and Community Land Use Board, 2010-2014. Planning, SUNY ESF, 2001. Project Scientist, Onondaga Environmental Institute, 2008-2010. Bachelor of Science, Environmental Policy and Management, SUNY ESF, 2001. Owner/Principal, Plan*It, 2007-2010. professional affiliations Neighborhood Planner, Home Headquarters, Inc., 2006-2007. Fellowship/International Exchange, Center for Environmental Studies, American Planning Association, New York Upstate Chapter. Vitoria- Gasteiz, Spain, 2005. Zen Center of Syracuse Board President, 2011-present Senior Planner, City of Syracuse Department of Community Open Hand Theater, Past Board President, 2007-2013. Development Division of Neighborhood Planning, 1999-2003. Leadership Greater Syracuse Graduate 2002. project experience Renewable Energy Permitting in New York- Prepared sections of applications submitted under Article 10 of the New York Public Service Law analyzing land use impacts of large-scale solar energy projects. Projects include: Riverhead 2, Suffolk County, NY- Conducted land use analysis and prepared Exhibit 4 for a proposed commercial solar power facility as part of an Article 10 application. Morris Ridge Solar Project, Montgomery County, NY- Conducted land use analysis for Exhibit 4 as part of an Article 10 application. Renewable Energy Permitting in Ohio- Prepared visual resource assessment reports for applications to the Ohio Power Siting Board (OPSB) for commercial scale solar power projects. Projects include: Yellowbud Solar Farm, Pickaway and Ross Counties, OH- Conducted visual impact analysis and prepared the subsequent report for the Certificate Application to the OPSB.

Archie Solar Farm (in progress), Fulton County, OH- Conducting visual impact analysis and preparing the subsequent report for the Certificate Application to the OPSB.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 1 www.edrdpc.com

SG-PF1 Page 1 of 3

Samuel Gordon Senior Project Manager

Brownfield Opportunity Area Strategic Investment and Implementation Strategy Corridor Plans, City of Syracuse, NY - oversaw the development of targeted investment strategies for redevelopment sites that were identified within the South Salina and Erie Boulevard East Brownfield Opportunity Areas. Oversaw the development of cost-benefit analyses for specific strategic sites within each BOA along with concept plan studies and visualizations to illustrate potential development opportunities as a result of the City’s ReZone effort. Concept studies were combined with detailed market profiles and branding materials for each BOA corridor. Empire State Development Corporation Downtown Revitalization Initiative, Round 4, City of Fulton, NY- Managed EDR team providing community outreach, presentation materials for public meetings, report design/layout, and conceptual graphics for lead consultant. Oversaw graphic production of renderings to depict streetscape improvements, and participated in public meetings to solicit public input on potential DRI implementation projects. Lake Ontario and St. Lawrence River Resilience and Economic Development Initiative (REDI), Wayne County, Cayuga/Oswego Counties, St. Lawrence/Jefferson Counties, NY – In collaboration with consultant team, assisted with the development and administration of the outreach effort for the REDI initiative. Responsible for facilitatitng all meetings in three regions: Wayne County Region, Cayuga/Oswego Counties Region, and St.Lawrence/Jeffserson Counties Region. Collaborated on developing the purpose, logistics, and execution of four stakeholder committee meetings and three public meetings in each of the three regions. Responsible for meeting logistics, facilitation, and summary. Meetings were conducted within a three months and concluded in September 2019. Comprehensive Plan Update (in progress), Town of Dryden, NY- managing the development of a comprehensive plan update for town located along a connecting corridor between the small cities of Ithaca and Cortland. Overseeing the research of ongoing demographic, land use, and policy/regulatory changes in the town; as well as planning initiatives at the county level influencing local issues. Coordinating steering committee involvement and overseeing the development and implementation of public engagement strategies in association with the project. LeMoyne Neighborhood Master Plan (in progress), Syracuse and DeWitt, NY – managing the EDR team working with the City of Syracuse, Town of DeWitt and LeMoyne college on the development of a community and economic revitalization plan for the neighborhoods surrounding LeMoyne College. Responsible for client communication and coordination; overseeing the development of a neighborhood housing market analysis; development of alternative mobility strategies; and strategies for integrating college programs and services into the surrounding neighborhoods. Responsible for the development and coordination of neighborhood engagement strategies. Local Waterfront Revitalization Plan (in progress), Old Erie Canal corridor, Madison/Oneida/Onondaga Counties, NY- Managing the development of an intermunicipal LWRP along a 36-mile corridor surrounding the Old Erie Canal State Historic Park, including adjacent nodes. Primarily responsible for the overseeing the inventory and analysis of current conditions, idenifying and developing community specific and corridor-wide revitalization strategies, and identifying and developing implementation projects. Also assisting with coordination issues related to the intermunicipal adoption processes. Community Development Strategic Plan (in progress), Herkimer County, NY - Project Manager for EDR as a subconsultant to Fairweather Consulting responsible for technical oversight of GIS-based parcel mapping, inventory and analysis of physical assets, natural resources and land use for all 17 towns, 10 villages, and the City of Little Falls in Herkimer County. Responsible for the development of an overlay analysis including mapping constraints and opportunities for economic development countywide by developing community profiles of each municipality and mapping environmental features, land use and zoning, transportation systems, public infrastructure and utilities; as well as a suitability analysis to identify priority locations and specific sites within the County that could support economic development to meet regional, County and local economic development goals and needs. Planning Board Services (ongoing), Town of DeWitt, NY – responsible for overseeing the review of site plan applications for the Town of DeWitt Planning Board including the review of plan documents, coordination with the Town Planning Board Chairperson and consultant team, communication with town staff and applicants. Director of Planning and Zoning, Town of Dewitt, NY - Department manager for Planning and Zoning functions for the Town of DeWitt inclusive of Code Enforcement with a budget of approximately $1 million. Responsible for the implementation of the Town Comprehensive Plan, coordinating site plan review, Town code revisions, grant writing and administration, GIS mapping, project development and administration. Procured multiple grants totaling approximately $500,000 including from the NYS Department of State the development of a Local Waterfront Revitalization Plan for Erie Canal related infrastructure within the Town, as well as funding to assist with the development of a Master Plan for the Hamlet of Jamesville. Oversaw Elevating Erie initiative leading to investment of over $20 million in the Empire State Trail through DeWitt. Oversaw the development and implementation of a mixed-use floating overlay zone for the town. Senior Planner, Central New York Regional Planning and Development Board, NY - Prior to EDR coordinated the Central New York Climate Change Innovation Program (C2IP), funded through the US EPA Climate Showcase Communities Program. Supervised the development of greenhouse gas inventories, climate action plans, and clean energy demonstration projects for 7 municipalities. In total nearly $3,000,000 in public and private investments were leveraged through project implementation (representing an almost 13:1 leverage ratio). Principal author for the Infrastructure chapter of the NYS Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 2 www.edrdpc.com

SG-PF1 Page 2 of 3

Samuel Gordon Senior Project Manager

Cleaner Greener Communities Vision CNY Regional Sustainability Plan in 2012. Co-developed and coordinated the Central New York Energy Challenge Team initiative, a behavior change program working with homeowners to encourage the adoption of conservation, efficiency, and renewable energy upgrades. The Challenge utilized a cooperative team-based approach to encouraging households to take action to reducing their energy consumption. Designed, developed, and maintained the agency website for the Central New York Energy Challenge http://www.cnyenergychallenge.org, as well as twitter @cnyenergy, facebook, and Linkedin Group (CNY RPDB Energy Management) Onondaga Creek Conceptual Revitalization Plan, Onondaga Environmental Institute, Syracuse, NY - Prior to EDR Responsible for the development of visualizations for proposed interventions along the Onondaga Creek Corridor for the Onondaga Creek Conceptual Revitalization Plan, developed the final report layout, and developed the OEI website. Conducted a regional open-space inventory for Onondaga County and developed a proposal for a countywide greenbelt system. Owner/Principal, Plan-It, NY - Prior to EDR Plan•it provided consulting expertise to clients throughout the Northeastern U.S. to develop strategies for revitalizing urban neighborhoods using a combination of GIS-based analysis, neighborhood visioning, and conceptual design. Developed a master plan for Sunnycrest Park in the city of Syracuse incorporating the use of green infrastructure elements, an urban nature trail for shared learning, and fostering hands- on nearby nature experiences. Syracuse Neighborhood Initiative, Syracuse, NY - Prior to EDR Responsible for the development and implementation of comprehensive revitalization strategies for neighborhoods within the city of Syracuse, including the development of new collaborations and innovative programs for neighborhood engagement. Conducted independent projects, including a comprehensive inventory of vacant and underutilized structures in collaboration with Clough Harbor and Assoc. for the “Creative Communities” initiative of the Metropolitan Development Association of CNY.

Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. 3 www.edrdpc.com

SG-PF1 Page 3 of 3

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

PRE-FILED TESTIMONY OF:

THOMAS JOHN CANNING, P.E.,

KIMLEY-HORN OF NEW YORK, P.C.

Case No. 17-F-0655 CANNING

1 Q: Please state your name, employer, and business address.

2 A: Thomas John Canning, P.E., Kimley-Horn of New York, P.C., 1 North Lexington Avenue, Suite

3 1575, White Plains, New York, 10601.

4 Q: What is your position at Kimley-Horn?

5 A: Associate and Director of Transportation Services for Kimley-Horn’s White Plains office.

6 Q: How long have you been employed with Kimley-Horn?

7 A: Three years and 4 months.

8 Q: Please describe your educational background and professional experience.

9 A: Bachelor of Engineering (Civil), Professional Engineer (NY, PA, CT). Practicing traffic engineering

10 since 1987 in New York, licensed since 1993, licensed in New York since 2010. I have over 30

11 years of experience undertaking and designing and overseeing a broad range of private and public

12 transportation projects involving large scale traffic impact studies, safety analyses, sight distance

13 analyses and truck turning analyses. Additional information on my experience is presented in my

14 curriculum vitae (CV), which is included as Exhibit ____ (TJC-PF1): Resume of Thomas John

15 Canning.

16 Q: Please describe your current responsibilities with Kimley-Horn.

17 A: Director of Traffic Engineering Services, White Plains Office. Responsible for directing the

18 preparation of traffic impact and traffic safety studies, for the preparation of Work Zone Traffic

19 Control plans and also for the design of traffic signals, signing and striping.

20 Q: Have you previously testified before the New York State Public Service Commission or

21 Siting Board on Electric Generation?

22 A: No.

23 Q: Have you previously served as an expert witness before any other court, agency, or other

24 body on the subject you plan to offer testimony on today?

Page 2 of 3

Case No. 17-F-0655 CANNING

1 A: I have provided testimony before numerous Zoning Boards of Appeal, Planning Boards, as well as

2 Town and Village Boards throughout New York over the course of the past 20 years on matters

3 relating to traffic impacts, traffic safety and transportation. I currently serve as the on-call traffic

4 consultant for the Towns of Goshen, Bedford and Greenburgh.

5 Q: What is the purpose and scope of your testimony in this proceeding?

6 A: To sponsor certain portions of the Riverhead Solar 2 Application or the Exhibits thereto.

7 Q: What portion(s) of the Application is your testimony sponsoring?

8 A: Effect on Transportation - Exhibit 25.

9 Q: Were these Exhibits, Application sections, or studies prepared by you or under your

10 direction and supervision.

11 A: Yes.

12 Q: In your testimony, will you refer to, or otherwise rely upon, any studies, publications, data

13 or documents produced by persons other than yourself/your company? If so, please cite

14 these sources.

15 A: Relevant references are listed in the Exhibit including, NYSDOT, Town of Riverhead and Suffolk

16 County data and records. Also, available Suffolk Transit, Riverhead Central School District (RCSD),

17 Town of Riverhead Volunteer Ambulance Corp. and Town of Riverhead Fire Department records.

18 Q: Does this conclude your testimony?

19 A: Yes.

Page 3 of 3

T. John Canning, P.E. Traffic and Transportation Engineer

John has 30 years of experience in the management of traffic and transportation projects and feasibility studies for northern New York City metro-area real estate, institutional, and government clients. He is a proven manager of both straight-forward development traffic-impact studies and complex transportation projects requiring multidisciplinary input, client and stakeholder coordination, and community outreach. John serves or has Professional served as an on-call traffic consultant to the Towns of Greenburgh, Bedford, Credentials Goshen, Cortlandt, and Woodbury as well as the Villages of Elmsford, Bachelor of Irvington, Tarrytown, Port Chester, and Nyack. Engineering, Civil Engineering, National Sample Experience University of Ireland, Dublin ⚫ Riverhead II Solar, Riverhead, NY - Project Engineer ⚫ Hamilton Green, White Plains, NY – Project Engineer Professional Engineer ⚫ The Collection, White Plains, NY - Project Manager in New York, ⚫ The Duet Residential Development, White Plains, NY - Project Manager Pennsylvania, and ⚫ White Plains YMCA, White Plains, NY - Project Engineer Connecticut ⚫ EF International Academy, Tarrytown, NY - Project Manager ⚫ Tarrytown YMCA, Tarrytown NY - Project Manager Professional ⚫ Medline Distribution Center, Montgomery, NY - Project Engineer Organizations ⚫ Chappaqua Form Based Code, New Castle, NY - Project Engineer Institute of ⚫ Point Street Landing, Yonkers, NY - Project Manager Transportation ⚫ Alder Manor, Yonkers, NY - Project Manager Engineers (ITE) ⚫ Ravine Avenue Master Plan, Yonkers, NY - Project Manager

⚫ Lionsgate Production Studio, Yonkers, NY - Project Manager ⚫ Boyce Thompson Center - Yonkers, NY - Project Manager ⚫ Bluestone Peak Academy, Somers, NY - Project Engineer ⚫ Greenwich Train Station, Greenwich, CT - Project Manager ⚫ Greenwich Country Day School (GCDS), Greenwich, CT - Project Manager ⚫ Cornell University Transportation Feasibility Study, Ithaca, NY - Project Manager ⚫ Halstead Avenue Transit-Oriented Development Plan, Harrison, NY - Project Manager ⚫ Hampshire Country Club Residential Development, Mamaroneck, NY - Project Engineer ⚫ Edge-on-Hudson Riverfront Redevelopment, Sleepy Hollow, NY - Project Engineer ⚫ Millers Pond Mixed-Use Development, Ramapo, NY - Project Engineer ⚫ Hudson Highlands Reserve, Philipstown, NY - Project Manager ⚫ Town Traffic Consultant, Goshen, NY ⚫ Town Traffic Consultant, Bedford, NY ⚫ Town Traffic Consultant, Greenburgh, NY ⚫ Village Traffic Consultant, Irvington, NY

1 Attachment 2 RIVERHEAD SOLAR – ELECTRONIC COPY SERVICE LIST

Case No. 17-F-0655, Application of Riverhead Solar 2, LLC for a Certificate of Environmental Compatibility and Public Need Pursuant to Article 10 for Construction of a Solar Electric Generating Facility Located in the Town of Riverhead, Suffolk County, New York.

Hon. Michelle L. Phillips Secretary to the Siting Board New York State Board on Electric Generation Siting and the Environment Empire State Plaza Agency Building 3 Albany, NY 12223-1350

(submission via DMM upload) (email service to: [email protected], [email protected], [email protected], [email protected])

Basil Seggos, Commissioner c/o Lisa Covert, Esq. NYS Department of Environmental Conservation 625 Broadway Albany, NY 12233

(email service to: [email protected]; [email protected])

Carrie Meek Gallagher, Regional Director NYSDEC, Region 1 SUNY @ Stony Brook, 50 Circle Road Stony Brook, NY 11790-3409

(email service to: [email protected])

Howard A. Zucker, Commissioner NYS Department of Health ATTN: William G. Sacks Senior Attorney, Bureau of Program Counsel Department of Health - Division of Legal Affairs 2468 Corning Tower Albany, NY 12237 (email service to: [email protected])

RIVERHEAD SOLAR – ELECTRONIC COPY SERVICE LIST

Hon. Anthony Belsito Administrative Law Judge Office of Hearings and Alternative Dispute Resolution Department of Public Service 3 Empire State Plaza, Albany, NY 12223

(Email service to: [email protected])

Hon. Molly McBride Administrative Law Judge Office of Hearings New York State Department of Environmental Conservation 625 Broadway Albany, NY 12233 (Email service to: [email protected])

NYSERDA Richard Kauffman, Chairman ATTN: Kelly Tyler 17 Columbia Circle Albany, NY 12203 (Email service to: [email protected])

Mr. Eric Gertler, Commissioner c/o Vincent Ravaschiere, Senior Vice President Energy & Incentives NYS Department of Economic Development 633 Third Ave, Fl 36 Albany, NY 12245 (Email service to: [email protected])

Yvette Aguiar, Supervisor c/o Town Attorney Robert Kozakiewicz Town of Riverhead 200 Howell Avenue Riverhead, NY 11901 (Email service to: [email protected])

Steven Bellone, County Executive H. Lee Dennison Building, 100 Veterans Memorial Highway P.O. Box 6100 Hauppauge, NY 11788-0099

RIVERHEAD SOLAR – ELECTRONIC COPY SERVICE LIST

(Email service to: [email protected])

NYS Dept. of Agriculture and Markets ATTN: Tara Wells 10B Airline Drive Albany, NY 12235

(Email service to: [email protected], [email protected])

NYS Attorney General Office of the Attorney General The Capitol Albany, NY 12224-0341

(Email service to: [email protected], [email protected])

Erik Kulleseid, Commissioner ATTN: Diana Carter NYS Office of Parks, Recreation and Historic Preservation Albany NY, 12238

(Email service to [email protected]; [email protected])

NYS Department of Transportation ATTN: Alexandra Benshoff 50 Wolf Road, 6th Floor Albany, NY 12232 (Email to: [email protected])

RIVERHEAD SOLAR – PAPER AND CD/USB COPY SERVICE LIST

NAME & ADDRESS NUMBER OF COPIES

Hon. Michelle L. Phillips 10 paper copies Secretary to the Siting Board 4 full sized drawing sets Empire State Plaza 1 USB drive of full Agency Building 3 application Albany, NY 12223-1350 1 USB drive of GIS shapefiles 1 copy of confidential materials

Basil Seggos, Commissioner 1 paper copy NYS Department of Environmental Conservation 1 USB Drive of Application ATTN: Lisa Convert, Esq. 1 full sized drawing set 625 Broadway 1 USB drive of GIS Albany, NY 12233 shapefiles

Carrie Meek Gallagher, Regional Director 1 USB Drive of Application NYSDEC, Region 1 1 USB drive of GIS SUNY @ Stony Brook, 50 Circle Road shapefiles Stony Brook, NY 11790-3409 1 full sized drawing set

Hon. Maria Villa 1 paper copy of NYSDEC Office of Hearings Application 625 Broadway 1 paper copy of Albany, NY 12233 confidential materials

Hon. Anthony Belsito 1 paper copy of Examiner Application NYS Dept. of Public Service 1 paper copy of Empire State Plaza confidential materials Agency Building 3 Albany, NY 12223-1350

Jason Mulford 1 full sized drawing set NYS Dept. of Agriculture and Markets 1 USB copy of Application AGM Senior Environmental Analyst 1 USB copy of GIS 450 Southline road shapefiles Galway, NY 12074

RIVERHEAD SOLAR – PAPER AND CD/USB COPY SERVICE LIST

NYS Department of Economic Development 1 abridged paper copy Commissioner’s Office (Exhibits only) 625 Broadway 1 CD Copy (Appendices Albany, NY 12245 and Figures)

Yvette Aguiar, Town Supervisor 1 paper copy of Application 200 Howell Avenue 1 full sized drawing set Riverhead, NY 11901

Steven Bellone, County Executive 1 paper copy of Application H. Lee Dennison Building, 100 Veterans Memorial Highway P.O. Box 6100 Hauppauge, NY 11788-0099

Rossana Rosado, Secretary of State 1 CD Copy NYS Department of State ATTN: Eric Hogan Director, Utility Intervention Unit 99 Washington Avenue Suite 640 Albany, NY 12231

Matthew Driscoll, Commissioner 1 CD Copy NYS Department of Transportation ATTN: Alexandra Benshoff 50 Wolf Road, 6th Floor Albany, NY 12232

Rose Harvey, Commissioner 1 CD copy to each address NYS Office of Parks, Recreation, and Historic Preservation 625 Broadway Albany, NY 12207

Rose Harvey, Commissioner NYS Office of Parks, Recreation, and Historic Preservation ATTN: John Bonafide Director, Technical Preservation Services Bureau Division for Historic Preservation Peebles Island State Park P.O. Box 189 Waterford, NY 12188-0189

RIVERHEAD SOLAR – PAPER AND CD/USB COPY SERVICE LIST

Riverhead Free Library 1 paper copy of Application 330 Court Street Riverhead, NY 11901

Riverhead Town Hall 1 paper copy of Application [Repository Copy] 200 Howell Avenue Riverhead, NY 11901

sPower 1 paper copy of Application 1 paper copy of confidential materials

Young/Sommer LLC 1 paper copy of Application 5 Palisades Drive, Suite 300 1 paper copy of confidential Albany, NY 12205 materials 1 full sized drawing set 1 USB copy of GIS shapefiles

Attachment 3

ATTORNEYS AT LAW

EXECUTIVE WOODS, FIVE PALISADES DRIVE, ALBANY, NY 12205 Phone: 518-438-9907 • Fax: 518-438-9914

www.youngsommer.com Writer’s Telephone: 272 [email protected]

June 24, 2020

Via First-Class Mail NYS Assemblyman Anthony Palumbo NYS Assembly District: 2 Albany Office LOB 546 Albany, NY 12248

Re: Case 17-F-01655: Notice of Riverhead Solar 2 Filing of Article 10 Application

Dear Assemblyman Palumbo:

As you may be aware, Riverhead Solar 2 (“Applicant”), proposes to construct a major electric generating Facility in the Town of Riverhead in Suffolk County, New York. To construct the facility, the Applicant is seeking a Certificate of Environmental Compatibility and Public Need (“CECPN”) from the New York State Board on Electric Generating Siting and the Environment (“Siting Board”) pursuant to Article 10 of the Public Service Law and the Siting Board’s rules (16 NYCRR Part 1000). In accordance with the requirements of 16 NYCRR 1000.7 (b)(2), enclosed please find a copy of the Notice that Riverhead Solar 2 is filing an Application in the above proceeding. This Notice is also being served on the host communities and stakeholders and published in local newspapers.

The Application contains detailed information regarding the proposed Riverhead Solar 2 Project, which is a solar-powered electric generation project consisting of up to 132.8 acres of photovoltaic (PV) solar panels generating up to 36 megawatts (MW) of electricity. The Facility will include solar panels, access roads, inverters, transformers, electrical collection lines, gen-tie line, and temporary construction staging and storage areas. The Facility will interconnect to the existing point of interconnection, Edwards substation, additional equipment will be added to the collection substation to support the interconnection of the Facility. The Project is proposed to be located on leased private land.

Once the Application is filed and determined by the Siting Board to be complete, the Siting Board will schedule a public hearing on the Application. Article 10 requires that all proceedings on the Application, including a final decision by the Siting Board, be completed within 12 months of when the Application is determined to be complete.

Please feel free to contact me if you have any questions regarding the above.

Yours truly,

James A. Muscato II Jessica Ansert Klami YOUNG/SOMMER LLC Attorneys for Riverhead Solar 2

Enclosure: Notice of Submission of Application

ATTORNEYS AT LAW

EXECUTIVE WOODS, FIVE PALISADES DRIVE, ALBANY, NY 12205 Phone: 518-438-9907 • Fax: 518-438-9914

www.youngsommer.com Writer’s Telephone: 272 [email protected]

June 24, 2020

Via First-Class Mail Yvette Aguiar, Supervisor Town of Riverhead 200 Howell Avenue Riverhead, NY 11901

Re: Case 17-F-0655: Notice of Riverhead Solar 2 Filing of Article 10 Application

Dear Supervisor Aguiar:

As you are aware, Riverhead Solar 2 (“Applicant”), proposes to construct a major electric generating Facility in the Town of Riverhead in Suffolk County, New York. To construct the facility, the Applicant is seeking a Certificate of Environmental Compatibility and Public Need (“CECPN”) from the New York State Board on Electric Generating Siting and the Environment (“Siting Board”) pursuant to Article 10 of the Public Service Law and the Siting Board’s rules (16 NYCRR Part 1000). In accordance with the requirements of 16 NYCRR 1000.7 (b)(2), enclosed please find a copy of the Notice that Riverhead Solar 2 is filing an Application in the above proceeding. This Notice is also being served on the host communities and stakeholders and published in local newspapers.

Please feel free to contact me if you have any questions regarding the above.

Yours truly,

James A. Muscato II Jessica Ansert Klami YOUNG/SOMMER LLC Attorneys for Riverhead Solar 2

Enclosure: Notice of Submission of Application

ATTORNEYS AT LAW

EXECUTIVE WOODS, FIVE PALISADES DRIVE, ALBANY, NY 12205 Phone: 518-438-9907 • Fax: 518-438-9914

www.youngsommer.com Writer’s Telephone: 272 [email protected]

June 24, 2020

Via First-Class Mail NYS Senator Kenneth P. LaValle NYS Senate District: 1 Albany Office LOB 809 Albany, NY 12247

Re: Case 17-F-0655: Notice of Riverhead Solar 2 Filing of Article 10 Application

Dear Senator LaValle:

As you may be aware, Riverhead Solar 2 (“Applicant”), proposes to construct a major electric generating facility in the Town of Riverhead in Suffolk County, New York. To construct the Facility, the Applicant is seeking a Certificate of Environmental Compatibility and Public Need (“CECPN”) from the New York State Board on Electric Generating Siting and the Environment (“Siting Board”) pursuant to Article 10 of the Public Service Law and the Siting Board’s rules (16 NYCRR Part 1000). In accordance with the requirements of 16 NYCRR 1000.7 (b)(2), enclosed please find a copy of the Notice that Riverhead Solar 2 is filing an Application in the above proceeding. This Notice is also being served on the host communities and stakeholders and published in local newspapers.

Please feel free to contact me if you have any questions regarding the above.

Yours truly,

James A. Muscato II Jessica Ansert Klami YOUNG/SOMMER LLC Attorneys for Riverhead Solar 2

Enclosure: Notice of Submission of Application

RIVERHEAD SOLAR 2 Suffolk County, New York

NOTICE OF SUBMISSION OF APPLICATION

Riverhead Solar 2, LLC (Applicant) is proposing to construct a major electric generating facility under Article 10 of the New York Public Service Law (Facility). This notice announces that on or about June 29th, 2020, the Applicant will file an Application pursuant to 16 NYCRR 1000.6 seeking a Certificate of Environmental Compatibility and Public Need from the New York State Board on Electric Generation Siting and the Environment (Siting Board) authorizing the construction and operation of the Facility.

The Facility is a proposed solar-powered electric generation project consisting of up to 132.8 acres of photovoltaic (PV) solar panels generating up to 36 megawatts (MW) of electricity to be located in the Town of Riverhead, Suffolk County. The Facility will include solar panels, access roads, inverters, transformers, electrical collection lines, gen-tie line, and temporary construction staging and storage areas. The Facility will interconnect to the existing point of interconnection at the Edwards Ave substation, and additional equipment will be added to the collection substation to support the interconnection of the Facility.

The Facility is a zero-emission solar energy facility that will assist the State in meeting the goals of the Climate Leadership and Community Protection Act and State Energy Plan, which includes obtaining 70% of energy generation from renewable sources by 2030 and significantly reducing greenhouse gas emissions. Other positive impacts of the Facility include diversification of energy supplies, new employment opportunities (both temporary construction employment and full-time jobs), and increased revenues to County and local tax bases, payments to the local hospitality industry, and purchase of local supplies and goods. In addition, the Applicant has attempted to minimize impacts to land associated with the Facility by limiting the disturbance to forested lands and wetlands to the maximum extent practicable. However, the construction and operation of the Facility may result in some environmental impacts as more fully described in the Application, including, but not limited to: impacts on terrestrial ecology and impacts to people, including noise, traffic and visual impacts.

Pursuant to the Article 10 process, the Applicant filed a Preliminary Scoping Statement (PSS) on September 14, 2018 with the Siting Board. After the public comment period on the PSS, the Applicant prepared a reply to material comments that was submitted on November 2, 2018. On November 8, 2018, a pre-application conference to consider intervenor funding requests was held and the scoping stipulation process was ordered to commence. On March 10, 2020, the Applicant filed executed stipulations regarding the scope of the Application. The Applicant is now ready to file an Application.

The Article 10 regulations outlining the required contents of the Application can be found at 16 NYCRR 1001.1 et seq. The Application includes, among other things: an analysis of the environmental setting of the Facility, a description of the Facility, including preliminary design drawings and related information; copies of reports, studies and plans submitted in support of the Application; an assessment of impacts of construction and/or operation of the Facility relating to land use; consistency with State energy planning objectives, including climate change and renewable energy goals; public health and safety; terrestrial ecology, water resources and aquatic ecology, including wetlands; communications, transportation and utilities; cultural, historical and recreational resources; visual, including glare; sound; electric magnetic fields; and impacts on the statewide electrical system.

Pursuant to the Article 10 process, this notice is being provided in accordance with 16 NYCRR 1000.7, and will be published at least three days prior to the filing of the Application. In addition, a copy of the Application will be served on the Chief Executive Officer of each municipality in which any portion of the Facility is located, as well as those persons and agencies enumerated in 16 NYCRR 1000.6.

Once an Application is filed and determined by the Siting Board to be complete, the Siting Board will schedule a public hearing on the Application. The Siting Board will also issue a notice of availability of application intervenor funds that are available to be used by parties to participate in formal review of the Application. A pre-hearing conference will be scheduled by the Hearing Examiner to identify intervenors, award intervenor funds, identify issues for the hearing, and establish a case schedule. Additional hearings regarding the application and project impact assessments will be scheduled by the Hearing Examiner as needed. After hearings, the stakeholders may brief their positions and the Hearing Examiner will issue a recommended decision upon which the Siting Board will base its decision. Article 10 requires that all proceedings on the Application, including a final decision by the Siting Board, must be completed within 12 months of when the Application is determined to be complete.

Upon filing the Application, the Applicant will provide funding in the amount of $36,000 to be disbursed by the Siting Board to municipalities and other local parties to help pay expenses, including attorneys and consultants, associated with participating in the Article 10 process during the application review phase. Fifty percent (50%) of these intervenor funds are reserved for municipalities. Following the filing of an Application, the Hearing Examiner or the Secretary will issue a notice of availability of application intervenor funds that provides a schedule and related information describing how interested members of the public may apply for application funds. Requests for application funds must be submitted to the Hearing Examiner within thirty (30) days after the issuance of the notice of the availability of application intervenor funds. Following the submittal of any intervenor funding requests, the Hearing Examiner may schedule a pre-hearing conference to consider fund requests. The record of this proceeding, including the Application, may be examined during normal business hours at the Offices of the New York State Department of Public Service (DPS) at 3 Empire State Plaza, Albany, NY 12223; and at the following public repositories: Riverhead Free Library, 330 Court Street, Riverhead, NY 11901. Libraries often have free internet access.

Contact Information Riverhead Solar 2, LLC DPS Article 10 Coordinator Michael Farrell James Denn 195 Montague Street NYS Department of Public Service 14th Floor, Suite 1461 3 Empire State Plaza Brooklyn, NY 11201 Albany, NY 12223 Tel. No. (855) 561-6212 Tel. No. (518) 474-7080 [email protected] [email protected]

The Application will also be available at the DPS website at (http://www.dps.ny.gov/). To access documents, go to “Search” on the top of the webpage and search using the Case Number 17-F-0655 or the direct link http://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=17-F-0655&submit=Search or by going to the Project-specific website maintained by the Applicant: riverheadsolar2.com

File a Request for Notices Any interested member of the public may file a request with the DPS Secretary to receive copies of all notices concerning the Project. Written requests should be sent to the DPS Secretary at [email protected] or sent by mail to the following address:

Honorable Michelle L. Phillips Secretary to the Siting Board NYS Board on Electric Generation Siting and the Environment Empire State Plaza Agency Building 3 Albany, New York 12223-1350

25 Town of a UV r Riverhead d

A C v R 5 e 8

Rd ver iver Ri econic R P UV24 ¨¦§495

Town of Brookhaven

Facility Site 1-mile Study Area µ Town Boundary 0 1,000 2,000 4,000 Feet

Riverhead Solar 2 Town of Riverhead, Suffolk County, New York Article 10 Application - Case No. 17-F-0655 Proposed Facility Notes: 1. Basemap: ESRI StreetMap North America, 2008. 2. This map was generated in ArcMap on June 22, 2020.

ATTORNEYS AT LAW

EXECUTIVE WOODS, FIVE PALISADES DRIVE, ALBANY, NY 12205 Phone: 518-438-9907 • Fax: 518-438-9914

www.youngsommer.com Writer’s Telephone: 272 [email protected]

June 29, 2020 Via Electronic Filing Hon. Anthony Belsito Administrative Law Judge NYS Department of Public Service Empire State Plaza Agency Building 3 Albany, NY 12223

Hon. Maria Villa Administrative Law Judge NYS Department of Environmental Conservation Office of Hearings and Mediation Services 625 Broadway, First Floor Albany, NY 12233

Dear Hearing Examiners:

We represent the Applicant, Riverhead Solar 2, LLC ("Riverhead Solar" or “Applicant”), in the above-referenced proceeding. On June 29, 2020, Riverhead Solar filed an Application under Public Service Law (PSL) Article 10 for the Riverhead Solar 2 Facility (the "Application"). The Application contains certain information which the Applicant asserts is confidential and should be protected from disclosure pursuant to the Siting Board's regulations.

As such, please find enclosed the Comprehensive Brief required by 16 NYCRR § 6-1.4 providing the basis for the Applicant's assertion of confidentiality. Copies of various documents for which the Applicant is seeking protection from disclosure are included with this letter. Certain materials that are either extremely bulky and/or were supplied to the appropriate agency staff separate from the above-referenced Application are not included with this submission. If you require copies of these documents in order to make the requested confidentiality determination, please let us know and we will supply them to you, unless specifically prohibited by applicable laws. If you have any questions, please feel free to let us know Please do not hesitate to call me with any questions.

Respectfully submitted,

James A. Muscato II Jessica Ansert Klami Attorneys for Riverhead Solar 2, LLC

cc: Party List (via DMM)

NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT ______

COMPREHENSIVE BRIEF IN SUPPORT OF CONFIDENTIAL PROTECTION OF CERTAIN APPLICATION MATERIALS

On or about June 29, 2020, Riverhead Solar 2, LLC (“Riverhead Solar” or “Applicant”) is filing an Application under Article 10 of the New York Public Service Law (PSL) seeking a

Certificate of Environmental Compatibility and Public Need (“Application”) to construct a 36 megawatt (MW) solar energy facility in the Town of Riverhead, Suffolk County, New York (the

“Facility”). Concurrent with that submission, Riverhead Solar hereby respectfully submits its brief in support of its request for confidential protection of certain documents and information contained within the Application, as specifically identified below.

LEGAL STANDARDS

Confidential protection is routinely granted to certain documents and data submitted to

State agencies and boards, including the New York State Board on Electric Generation Siting and the Environment (“Siting Board”) and New York State Public Service Commission

(“Commission” or PSC), through a suite of statutory and regulatory protections which guard such sensitive information and data from broad public release. As more fully discussed below, these protections are derived from various sources, including the statutory exemptions from disclosure under the New York Freedom of Information Law (FOIL), Public Officers Law (POL) § 87, as well as through each agency’s regulations—in this case, 16 NYCRR § 5.8(e) and Part 6. Other statutes such as the New York Environmental Conservation Law (ECL) provide additional protection for certain information. See e.g., ECL § 3-0301(2)(r) (protecting data on habitats of protected species). Finally, certain information is entitled to traditional evidentiary privileges used in civil courts and articulated in the Civil Practice Law and Rules (CPLR). See 16 NYCRR §

5.8(d).

In this case, submission of the identified confidential information is required as part of the

Application for a Certificate of Environmental Compatibility and Public Need under PSL Article

10, PSL § 164 and 16 NYCRR § 1001 or to comply with commitments made by the Applicant in the Stipulations executed in this proceeding. The confidential information will be submitted to the

Presiding Examiners under separate cover and will be accompanied by this request from the

Applicant for confidentiality protections, including exemption from public disclosure under FOIL and in accordance with 16 NYCRR § 6-1.4.

With respect to the recently submitted Application for the Facility, the Applicant is requesting confidentiality protection as follows:

• Protecting as confidential information pertaining to the location of endangered, protected,

threatened or rare animal species or protected plants pursuant to ECL § 3-0301(2)(r).

• Protection of critical energy infrastructure information (CEII) pursuant to POL § 86(5)

(defining critical infrastructure) and POL § 89(5)(a)(1-a) (addressing requests for

confidentiality for CEII).

• Protection of location of archaeological resources pursuant to New York State Parks,

Recreation and Historic Preservation Law § 14.07.

• Protection of trade secret and/or confidential commercial information pursuant to POL §

87(2)(d).

• Protection of individual names and addresses and related information pursuant to POL §

87(2)(b).

Page 2 of 19

CONFIDENTIALITY ANALYSIS

Riverhead Solar seeks confidential protection for certain information contained in the

Application (i.e., the Exhibits) as well as well as various Appendices to the Application, and electronic shapefiles which provide the same information in a format requested by the NYSDPS and NYSDEC staffs to aid in their review of certain Application data. The specific submissions and grounds for requesting confidential protection are discussed below.

As required by the regulations, Riverhead Solar is submitting this information to the

Presiding Examiners under separate cover seeking confidential protection. 16 NYCRR §§ 6-1.3 and 6-1.4. Where a document contains both confidential and non-confidential information,

Riverhead Solar has included a redacted version of the document with the Application and submitted a non-redacted version to the Presiding Examiners in conjunction with the request for a confidentiality determination.

I. Information Relating to Endangered, Threatened or Protected Species

New York Public Officers Law § 87(2)(a) grants a FOIL exemption to any information that is specifically identified as protected from disclosure under other provisions of State or federal law. ECL § 3-0301(2)(r) specifically authorizes the New York State Department of Environmental

Conservation (DEC) to “deny access to inspection of records which identify locations of habitats of species” designated as endangered, threatened or species of special concern under ECL § 11-

0535, plants protected under ECL § 9-1503, or “any other species or unique combination of species of flora or fauna where the destruction of such habitat or the removal of such species therefrom would impair their ability to survive.” The State has determined that the environmental protections advanced by keeping this information confidential—protecting the locations where protected species live, roost, gather, or winter to prevent the injury or death by hunters or the disturbance of critical habitat by human visitors—outweighs the public’s general interest in free access to

Page 3 of 19 government information. In the past, the Commission and Siting Board have relied on ECL § 3-

0301(2)(r) to protect information about the habitat of protected species from disclosure. See, e.g.,

Case 98-F-1968, Ramapo Energy Limited Partnership, Ruling on Motion and Protective Order

(Feb. 14, 2001); Case 12-T-0248, New York State Electric & Gas Corp., Ruling Granting Requests for Protection of Information Concerning Critical Electrical Infrastructure and Rare, Threatened, or Endangered Species (Oct. 17, 2013).

The only requirement for obtaining this type of confidentiality protection is that an

Applicant identify the data or document as containing information relating to the habitat of endangered, protected or threatened species. So long as information of that nature is in fact found there, agencies will afford the requested protection.

With respect to the Application, Riverhead Solar is seeking confidential protection for all or portions of the following documents under ECL § 3-0301(2)(r):

• Exhibit 2, Overview and Public Involvement, redacted to protect information relating to

endangered, threatened and/or protected species.

• Exhibit 9, Alternatives, redacted to protect information relating to endangered, threatened

and/or protected species.

• Exhibit 22, Terrestrial Ecology and Wetlands, redacted to protect information relating to

endangered, threatened and/or protected species.

• Application Appendix 22-E, Endangered and Threatened Species Memo, submitted

confidentially to protect information relating to endangered, threatened and/or protected

species.

• Application Appendix 22-G, NYSDEC Concurrence Correspondence submitted

confidentially to protect information relating to endangered, threatened and/or protected

species.

Page 4 of 19

• Application Appendix 22-I: NYSDEC Jurisdictional Determination Addendum Request

Response submitted confidentially to protect information relating to endangered,

threatened and/or protected species.

• Appendix 22-K: Updated Wetland Delineation Report to USACE redacted to protect

information relating to endangered, threatened and/or protected species.

• Appendix 22-M: Wetland Functions and Values Assessment Memo redacted to protect

information relating to endangered, threatened and/or protected species.

The listed documents contain information about endangered, protected, threatened or rare species and their habitats, including the presence or absence of those species in a particular area, the use by those species of certain habitat, and/or the location of critical habitat. This information is entitled to confidentiality protection under ECL § 3-0301(2)(r) without any further showing.

II. Critical Energy Infrastructure Information

Protection of critical energy infrastructure information (CEII) happens largely automatically once a party submits the data, information or documents and flags them as containing CEII. POL § 86(5) defines “critical infrastructure” as “systems, assets, places or things, whether physical or virtual, so vital to the state that the disruption, incapacitation or destruction of such systems, assets, places or things could jeopardize the health, safety, welfare or security of the state, its residents or its economy.” CEII is information which, by its very nature, must be kept confidential. The State has determined that the public interest is served best by maintaining CEII as strictly confidential, even if that means that the public is denied access to that information.

POL § 89(5)(a)(1-a) allows any person or entity making a submission that contains CEII to request protection of that information from disclosure and further protects the request itself as confidential where disclosure of the information contained in the request would defeat the purpose of the requested protection. That information can be considered exempt from disclosure under

Page 5 of 19

POL § 87(2)(f)’s protection of information which, if disclosed, “could endanger the life or safety of any person” and/or § 87(2)(i)’s protection of information which, if disclosed, “would jeopardize the capacity of an agency or an entity” to ensure the security of its information technology assets, including electronic information system and infrastructure. In fact, the Commission and the New

York State Department of Public Service (DPS) themselves are directed by POL § 89(5)(a)(3) to maintain CEII apart from all other agency records to ensure proper protection.

In many cases, the applicant is provided access to CEII only after signing a non-disclosure agreement or other contract with the New York Independent Systems Operator (NYISO), the

Federal Energy Regulatory Commission (FERC), utilities or other entities; public disclosure of that CEII upon its submission by the applicant would likely violate the commitments the applicant made to obtain that information in the first instance.

With respect to the Application, Riverhead Solar is seeking confidentiality protection for the following documents as CEII:

• Application Appendix 5-A, System Reliability Impact Study (SRIS).1

• Application Exhibit 5, Electric System Effects, and Exhibit 8, Electric System Production

Modeling, redacted to protect CEII, which includes information about and discussion of

potential constraints and weaknesses in the State’s energy infrastructure and disclose

technical and locational details of electrical systems and which, if disclosed, could result

in a threat to the public health, safety and welfare.

• Electronic shapefiles which contain CEII locations (to be submitted to authorized DPS

Staff only under separate, confidential cover).

1 This document has been submitted under separate cover only to those DPS Staff members authorized to receive sensitive CEII information. The document is not included here, given the limitations on its release. However, should Your Honors require a copy of the OSRIS to make a determination as to its confidentiality, the Applicant will contact the NYISO to determine the best method for so doing.

Page 6 of 19

The DPS and PSC have consistently held that the vast majority of the information contained in the OSRIS should be protected from disclosure as CEII. See Case 06-T-0650,

Application of New York Regional Interconnect, Inc., Ruling Granting Protection for Critical

Energy Infrastructure Information, p. 3 (July 31, 2008) (disclosure of SRIS “has the potential to lead to disruption of New York's power system, which could endanger the life and safety of the public”); Case 08-T-0746, Application of the Village of Arcade and Noble Allegany Windpark,

LLC, Ruling Granting Request for Confidential Status, p. 2 (July 30, 2008) (finding that all of the

SRIS except the Executive Summary and Sections 1 and 2 of the SRIS should be exempted from disclosure); see also Case 08-T-0034, Application of Hudson Transmission Partners, LLC, Ruling

Granting Protection for Critical Energy Infrastructure Information (Apr. 25, 2008); Case 07-T-

0140, Application of Noble Wethersfield Windpark, LLC, Ruling Granting Protection from

Disclosure for Critical Infrastructure Information (Mar. 15, 2007). Documents such as the OSRIS and Generation Dispatch Forecasting Analysis required for all proposed Article 10 projects are routinely considered confidential CEII because they include information related to transformer settings, potential weaknesses in the system, overhead transmission standards, and other similar information that qualifies as critical infrastructure information. Furthermore, NYISO considers its power flow, stability and short-circuit data—which are included in the OSRIS—as critical energy infrastructure information, and restricts access to this information to parties who agree not to disclose the data to other parties.

Where the Applicant has identified that a given submission contains CEII, POL §

89(5)(a)(1-a) provides automatic protections for that information to prevent its disclosure and protect the public health, safety and security of the electric grid. No further showing is required.

The availability of this exemption is triggered by the presence of CEII.

Page 7 of 19

As identified above, CEII data submitted by the Applicant includes the SRIS (Appendix 5-

A), Exhibit 8’s electric system modeling files, and certain electronic files containing CEII locations. These submissions contain data sourced from NYISO on power flow, stability, and short circuit information, and discussions which disclose the specific locations and/or weaknesses or vulnerabilities of electric infrastructure, which could be damaging to the grid and the public if disclosed. Consistent with the definition of critical infrastructure in POL § 86(5), these submissions address “systems, assets, places or things, whether physical or virtual, so vital to the state that the disruption, incapacitation or destruction of such systems, assets, places or things could jeopardize the health, safety, welfare or security of the state, its residents or its economy.”

Accordingly, the identified CEII submitted by Riverhead Solar should be granted confidential protection.

III. Location of Archaeological Resources

POL § 87(2)(a) grants a FOIL exemption to any information that is specifically identified as protected from disclosure under other provisions of State or federal law. Both the federal and

State historic preservation acts contain provisions authorizing agencies to withhold from disclosure information on the location of archaeological sites to protect against possible damage. Of particular note, New York State Historic Preservation Law § 14.07 authorizes the withholding of information on archaeological sites from the public where sites “may be damaged by unauthorized investigators if their locations be generally publicized.” See 9 NYCRR § 427.8; see also 54 USC

§ 307103(a) (authorizing federal agencies to withhold from public disclosure information on the location of historic property if it is determined that disclosure may risk harm to the property).

Consistent with these provisions, the Commission has recognized the need to protect the location of archaeological sites from disclosure. See, e.g., Case 12-T-0248, Application of New York State

Electric & Gas Corp., Order on Waiver Requests (Sept. 14, 2012).

Page 8 of 19

With respect to the Application, Riverhead Solar is seeking confidential protection for

Application Appendix 20-B, Phase 1B Archaeological Survey Report, which summarizes the results of the comprehensive review of archaeological resources on the Facility Site. These documents include pictures and locations of protected cultural resources and areas. This information was assembled for purposes of assessing the impact of the Facility on these resources and enabling the Applicant to locate the Facility away from these resources where possible.

Making this information available to the public would facilitate identification/location of these resources, increasing the potential risk of damage by third parties. Consistent with the laws identified above, the Presiding Examiners should protect this information from disclosure. The

State has determined that the goals advanced by keeping this information confidential—protecting the locations where archaeological resources may be found to prevent harm to those resources by

“unauthorized investigators”—outweighs the public’s general interest in free access to government information.

IV. Trade Secrets and Confidential Commercial Information

Various documents submitted with the Application should be deemed exempt from disclosure under FOIL as “trade secrets” or records “submitted to an agency by a commercial enterprise or derived from information obtained from a commercial enterprise and which if disclosed would cause substantial injury to the competitive position of the subject enterprise.” POL

§ 87(2)(d). This exemption protects the interests of a commercial enterprise in avoiding a significant competitive injury as a result of disclosure of information provided to an agency, thereby fostering the State's economic development efforts to attract business to New York. See

Matter of Encore Coll. Bookstores, Inc. v. Auxiliary Serv. Corp. of State Univ. N.Y. at

Farmingdale, 87 N.Y.2d 410, 420 (1995).

Page 9 of 19

The Commission and Siting Board’s Rules of Procedure define "trade secret" as "any formula, pattern, device or compilation of information which is used in one's business, and which provides an opportunity to obtain an advantage over competitors who do not know or use it." 16

NYCRR § 6-1.3(a). One who seeks trade secret protection for information submitted to the Siting

Board must demonstrate why the information should not be disclosed as provided for in POL §

87(2)(d). The following six non-exclusive factors are to be considered in making the required determination:

(i) the extent to which the disclosure would cause unfair economic or competitive damage; (ii) the extent to which the information is known by others and can involve similar activities; (iii) the worth or value of the information to the person and the person's competitors; (iv) the degree of difficulty and the cost of developing the information; (v) the ease or difficulty associated with obtaining or duplicating the information by others without the person's consent; (vi) other statute(s) or regulations specifically excepting the information from disclosure.

16 NYCRR § 6-1.3(b)(2). Documents found to be trade secrets are exempt from disclosure without further inquiry. Verizon New York Inc. v. New York State Pub. Serv. Comm’n, 137 A.D.3d 66 (3d

Dept. 2016).

“Whether information is a trade secret depends, in part, upon the ease or difficulty with which the information could be acquired or duplicated by others.” Verizon New York Inc. v. New

York State Pub. Serv. Comm’n, 46 Misc. 3d 858, 872-73 (NY Sup. 2014), affirmed, 137 A.D.3d

66 (3d Dept. 2016) (quoting Savannah Bank v. Savings Bank of Fingerlakes, 261 A.D.2d 917, 918

(4th Dept.1999)). “Thus, the rationale for not subjecting a trade secret to a further requirement of showing ‘substantial injury’ to the commercial enterprise's competitive position likely stems from the fact that the definition of the term already takes into account that such information took

Page 10 of 19 considerable effort and resources to develop, has real economic value to the business and gives the business an advantage over competitors who are unaware of it.” Id. at 873.

Certain documents and commercial information may not rise to the level of bona fide trade secrets, but may nevertheless be entitled to protection as confidential commercial information where the owner of the documents or information demonstrates that disclosure of that information could cause substantial injury to the owner’s competitive position. Verizon New York, Inc., 137

A.D.3d at 74 (outlining a “two-part inquiry” to determine whether information satisfies the trade secret exemption and, if not, whether it nevertheless satisfies the “substantial competitive injury standard”). Consistent with POL § 87(2)(d) as interpreted by the courts, information is

“confidential commercial information” where it is (1) confidential or non-public information of a commercial nature which (2) would, if disclosed, cause substantial competitive injury.

The Court of Appeals has affirmed the need for this exemption in finding that

[b]ecause competition in business turns on the relative costs and opportunities faced by members of the same industry, there is a potential windfall for competitors to whom valuable information is released under [Freedom of Information Act (FOIA)]. If those competitors are charged only minimal FOIA retrieval costs for the information, rather than the considerable costs of private reproduction, they may be getting quite a bargain. Such bargains could easily have competitive consequences not contemplated as part of FOIA's principal aim of promoting openness in government.”

Encore College Bookstores, Inc., 87 N.Y.2d at 420 (quoting Worthington Compressors v. Costle,

662 F.2d 45, 51 (D.C. Cir. 1981)). Accordingly, the central inquiry with respect to confidential commercial information is the potential value of the requested information to competitors. Id.

(“[b]ecause the submitting business can suffer competitive harm only if the desired material has commercial value to its competitors, courts must consider how valuable the information will be to the competing business, as well as the resultant damage to the submitting enterprise”). The entity seeking protection is not required to prove actual competitive harm; only that there exists “actual

Page 11 of 19 competition and the likelihood of substantial competitive injury.” Id. at 421 (quoting Gulf &

Western Industries v. United States, 615 F.2d 527, 530 (D.C. Cir. 1980)). Courts will also examine the potential economic windfall that might result to competitors should the requested information be disclosed. See, e.g., New York State Elec. & Gas Corp. v. New York State Energy Planning Bd.,

221 A.D.2d 121, 125 (3d Dept. 1996) (permitting exemption from disclosure for operational data of cogeneration facility based on substantial injury to the competitive position of the subject enterprise because “the data sought is not public information and . . . the disclosure of such data could result in competitors, like petitioner, inferring essential aspects of [company’s] production costs fundamental to projecting future costs”); City of Schenectady v. O’Keeffe, 50 A.D.3d 1384,

1386 (3d Dept. 2008) (data had commercial value not only to the commercial enterprise—a utility—but also to the enterprise’s competitors, where compiling that data was “a costly and complex endeavor that entails an exhaustive review” by the utility).

As the above summary suggests, the chief distinction between “trade secret” and confidential commercial information is whether the entity seeking protection must demonstrate that it will be harmed by disclosure. For confidential commercial information, the Applicant needs to show why the information, if disclosed, would be likely to cause substantial injury to the competitive position of the subject commercial enterprise. Verizon New York, 137 A.D.3d at 72-

73. By comparison, documents found to be trade secrets are exempt from disclosure without further inquiry. Id. at 73 ("it is wholly unnecessary and overly burdensome to require the entity to

. . . make a separate showing that FOIL disclosure of the trade secret would cause substantial injury to its competitive position").

Various information submitted with the Application should be protected from disclosure as either trade secret or confidential commercial information. The information is organized by

Page 12 of 19 broad category and analyzed under the disclosure exemptions for trade secrets and/or confidential commercial information as appropriate.

A. Electric Generation Information

The following information relating to electric generation is eligible for trade secret protection:

• Application Exhibits 5 and 8, selected redactions of text and tables containing proprietary

data such as spot pricing analysis, output capability analysis, and resource analysis,

developed at significant difficulty and cost to the Applicant.

• Application Appendix 8-A, Generation Dispatch Forecasting Analysis, which primarily

contains CEII, but also includes project-specific modeling involving proprietary data such

as spot pricing analysis, output capability analysis, and resource analysis.

Output capability analyses, capacity analyses and resource analyses, energy production projections and other similar information are precisely the type of information protected as “trade secrets” since they are information and data “which is used in one’s business, and which provides an opportunity to obtain an advantage over competitors who do not know or use it.” 16 NYCRR §

6-1.3(a). This information is critical to the Applicant’s ability to develop competitive generation projects and fulfills many of the criteria in 16 NYCRR § 6-1.3(b) for identifying trade secret information. Among other things, (1) assembling the information required considerable investments of time, money and human capital; (2) the information is regularly preserved as confidential by the Applicant and is not known by others. As a result, it could not be readily obtained or duplicated by others without the Applicant’s consent; and (3) the information would be extremely valuable to the Applicant’s competitors who could use the information to undermine

Applicant’s position in the competitive wholesale power marketplace to gain a competitive advantage over the Applicant. In light of the confidential nature of this information, the Applicant

Page 13 of 19 routinely requires execution of non-disclosure agreements prior to releasing this sensitive information to vendors and experts and regularly seeks confidential protection of this information from release by regulatory entities. For the foregoing reasons, this information is protected trade secret information and is therefore exempt from disclosure.

B. Project Cost Information

The following information relating to the cost of the Project is eligible for trade secret and/or confidential commercial information protection.

• Application Appendix 14-A, Capital Cost Information, the capital cost information is a

compilation of financial information used to help the Applicant determine the total cost of

the Facility.

• Application Exhibit 27, redacting limited proprietary financial information relating to land

lease payments and other highly sensitive project-specific assumptions used to model the

socioeconomic impact of the Facility.

The information is entitled to trade secret protection as information and data “which is used in one’s business, and which provides an opportunity to obtain an advantage over competitors who do not know or use it.” 16 NYCRR § 6-1.3(a). See, e.g., Case 05-E-1222, New York State Electric and Gas Corp., Rule Granting Trade Secret Protection to NYSEG’s Mobile Radio System Cost

Estimates (Oct. 13, 2005) (concluding mobile radio system cost estimates provided with rate filing qualified for trade secret protection). Information relating to the cost of constructing the proposed

Facility is not known by or available to competitors and is closely guarded by the Applicant to protect its competitive position. Release of this information would compromise the Applicant’s ability to compete in the marketplace.

Information involving the capital cost of construction was generated through the use of proprietary company formulas and strategies unknown to others outside of the company and

Page 14 of 19 reflects a compilation of engineering, vendor and business information which the Applicant has thus far kept confidential. The information generated relating to decommissioning costs was obtained via a similar process. Information had to be compiled, gathered, developed, generated and analyzed by the Applicant or its consultant and involved the investment of significant time, resources, human capital, and business experience not available to other companies. It would be impossible for Applicant’s competitors to obtain this information from other sources. In fact, public disclosure of the Applicant’s trade secrets is the only manner in which the Applicant’s competitors could obtain this information, which would put Applicant at a clear and significant disadvantage.

Given the significant competition for contracts and awards, loss of any competitive advantage matters. If a competitor has access to an applicant’s capital cost information, it can more accurately anticipate the applicant’s energy price and bid submissions, and can use that information to win solicitations and contracts.

Even if this information does not qualify for trade secret protection, it is nevertheless entitled to protection as confidential commercial information which, if disclosed, would cause the

Applicant substantial competitive and economic injury. See, e.g., Case 08-T-0034, Hudson

Transmission Partners, LLC, Ruling Granting Protection for Project’s Estimated Capital Costs

(Mar. 6, 2008) (granting applicant’s capital cost estimate protection from disclosure as confidential commercial information); see also Case 14-T-0360, Dunkirk Gas Corp., FOIL Determination

Regarding Exhibit 9 (Oct. 14, 2014) (concluding release of cost estimates would undermine competitive bidding process giving rise to substantial likelihood that Applicant would suffer actual and substantial injury as a result of its release and justifying exempting information from disclosure as confidential commercial information).

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As previously noted, commercial information that is confidential includes non-public information which is developed, often at a substantial cost to the enterprise, to further the company’s standing in the market, the resources available at its disposal, the financial or other analysis used to steer decisions and inform strategies, and which is generally used in the conduct of one’s business. Details on company and project finances, including capital cost information, are among the types of information commonly considered confidential information of a commercial nature and should be protected from disclosure here.

C. Manufacturer Related Information

The following information relating to the equipment under consideration is eligible for trade secret protection:

• Application Appendix 11-G: Equipment Technical & Safety Manuals

The Commission has found that technical documents which are costly to produce and which were clearly intended to be kept confidential are entitled to "trade secret" protection. See Re: Appeal of

Determination Concerning Request for Records Submitted by My Norlander on June 17, 2014

(Filed in DPS Case 14-M-0183), 14-M-0183, 2014 WL 4102107 at 22 (Aug. 15, 2014). In this case, each of the technical documents listed above were supplied to the Applicant by various vendors as trade secrets and may be subject to non-disclosure agreements between the vendors/manufacturers and the Applicant. The example safety technical manuals (Appendix 11-

G) contain detailed information relating to the design, construction and operation of the equipment under consideration that was supplied by the manufacturers to the Applicant (a potential customer) to enable the Applicant to consider the relative merits of the manufacturers' products. For obvious reasons, detailed information regarding the configuration and operation of this equipment is extremely valuable to competing manufacturers. As a result, the manufacturers have gone to great lengths to protect this information from competing manufacturers, including requiring the

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Applicant to sign non-disclosure agreements. Disclosing this information as part of the Application could violate the non-disclosure agreement and result in the revelation of trade secrets sought to be maintained by the vendor/manufacturer and should therefore be protected from disclosure here.

V. Personal Information and Drinking Water Data

Pursuant to POL § 87(2)(b), an agency may deny access to records or portions thereof where the information "if disclosed would constitute an unwarranted invasion of privacy under the provisions of subdivision two of section eighty-nine of this article." POL § 89(2), in turn, authorizes agencies to adopt guidelines regarding deleting identifying details or withholding records to prevent privacy invasions and to authorize agencies to delete identifying details when it makes records available. The statute includes a non-exclusive list of actions that are considered unwarranted invasions of privacy.

Furthermore, as stated by the New York State Department of Health in confidentiality agreements required to obtain drinking water intake information maintained by the NYSDOH,

“secure public water supply systems are a prerequisite for ensuring safe drinking water and protecting public health, and as such all records and other information pertaining to the critical infrastructure of public water supply systems are exempt from disclosure” under FOIL. As noted in Section II of this brief, POL § 86(5) defines “critical infrastructure” as “systems, assets, places or things, whether physical or virtual, so vital to the state that the disruption, incapacitation or destruction of such systems, assets, places or things could jeopardize the health, safety, welfare or security of the state, its residents or its economy.” Critical infrastructure is not limited to electrical systems; by definition, this must include water infrastructure which, if identified publicly, could jeopardize the health, safety, welfare or security of the State and its residents.

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The Applicant asserts that the following information is eligible for protection under POL

§ 87(2)(b), and/or eligible for protection as drinking water source information which, if released, could threaten the health and safety of the public:

• Appendix 23-A, NYSDOH Water Well Data and Private Well Survey Results, redacted to

exclude details relating to public and private drinking water wells.

• Figure 23-4, redacted to exclude details relating to public and private drinking water

sources.

• Appendix 2-A, Master List of Stakeholders, redacted to remove names and email addresses

for individuals in the interests of preserving personal privacy.

With respect to the Water Well Data and Private Well Data (Appendix 23-A and Figure

23-4), to satisfy its obligations under the Article 10 regulations, the Applicant sent water well surveys to residences/businesses in close proximity to the proposed Facility in order to obtain information about the configuration of their groundwater wells, which enabled the Applicant to assess groundwater conditions at the Facility Site and avoid potential impacts. The completed surveys contain contact information about the property owner as well as detailed information about their well that is not necessarily available from public sources. Consistent with POL § 87(2)(b), these surveys should be protected from disclosure to preserve the confidentiality of names and addresses of the well owners. Moreover, declining to provide such privacy protections to the private water survey results may discourage others from participating in such surveys, depriving applicants and the State of information relevant to assessing the potential impact of proposed facilities on groundwater.

Furthermore, the Applicant executed a confidentiality agreement with the NYSDOH to obtain information regarding public drinking water sources and locations in the vicinity of the

Project Site. This information was only provided to the Applicant under the condition that it be

Page 18 of 19 protected from public release, and in acknowledgement of the potential harm to the public health and safety which could result from the public release of such information. Protecting both public and private drinking water information from disclosure will ensure that location and other information regarding the wells is not readily available to those who may wish to do harm to such water supplies, and the residents and businesses who depend on them.

Lastly, the Applicant has redacted email addresses and individual names from the Master

Stakeholder List, in the interests of protecting personal privacy of those individuals. Some members of the Master Stakeholder List were added because they asked to receive notices, but those individuals did not give consent for the public posting of their personal contact information in asking to receive those notices.

CONCLUSION

For all of the reasons listed above, the items identified by the Applicant should be exempted from public disclosure. Should you have any questions regarding this filing, please contact me.

Respectfully submitted,

James A. Muscato II Jessica Ansert Klami Young/Sommer LLC Attorneys for Riverhead Solar 2, LLC

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