Vineyard Wind Connector:
Cape Cod Commission Development of Regional Impact
February 8, 2019
Submitted to Prepared by Cape Cod Commission Epsilon Associates, Inc. 3225 Main Street 3 Mill & Main Place, Suite 250 Barnstable, MA 02630 Maynard, Massachusetts 01754
Submitted by In Association with Vineyard Wind LLC Foley Hoag LLP 700 Pleasant Street, Suite 510 Stantec, Inc. New Bedford, Massachusetts 02740 Geo SubSea LLC
February 8, 2019
Mr. Jonathon Idman, Esq. Submittal via email Chief Regulatory Officer Cape Cod Commission 3225 Main Street Barnstable, MA, 02630
Subject: Vineyard Wind Connector, Draft Application Cape Cod Commission, Development of Regional Impact Review
Dear Mr. Idman:
On behalf of Vineyard Wind LLC (the Company, or Proponent), I am pleased to submit this application for the Cape Cod Commission’s Development of Regional Impact (DRI) review for the jurisdictional elements of the Vineyard Wind Connector1. In preparation for this submittal, our team has met with you, Executive Director Senatori, and your colleagues for several discussions over the past year. We have enjoyed the opportunity to provide an overview of our Project and appreciate the feedback and guidance which you have provided. We also appreciate the constructive comments which you and your staff have provided during the course of the year-long MEPA review, which has recently concluded with the issuance of the MEPA Certificate on the FEIR issued February 1, 2019.
From the beginning, Vineyard Wind’s development has been stakeholder-driven, starting with the multi-year federal process to identify those areas of the Outer Continental Shelf that strike the best balance among the varied and important maritime interests, to the Commonwealth’s establishment of climate change goals through the 2008 Massachusetts Global Warming Solutions Act and the opportunity to expand offshore wind and other renewables through the state’s 2016 Energy Diversity Act.
We believe that both the public dialogue and the policy framework around offshore wind presents a terrific opportunity to build a responsibly sited and carefully designed offshore wind project; a project that will garner broad support from the Cape, help to achieve the state’s renewable energy goals, and stand as a national model. The Vineyard Wind project is a crucial step in our national effort to address
1 The Vineyard Wind Connector includes the Massachusetts-jurisdictional elements of the 800 MW Vineyard Wind Project. The Massachusetts elements include most of the offshore export cables, the onshore underground cables, the proposed onshore substation, and the grid interconnection. The jurisdictional Barnstable County elements include 8.4 miles of the offshore export cables together with all onshore elements of the Connector. The wind turbine array is in federal waters with the nearest turbine located nearly 15 miles south of Martha’s Vineyard and more than 30 miles south of the Cape.
threat of climate change and is a unique opportunity for the Cape to play a pivotal role in addressing this local, regional and global challenge.
The balance of this letter provides an update on Project milestones, an overview of key refinements and improvements made over the past several months, an update on the BOEM review process and some closing thoughts on the importance of this groundbreaking utility scale renewable energy Project to the Commonwealth’s effort to aggressively reduce emissions of greenhouse gases.
Recent Project Milestones
Progress on DPU Review of the Power Purchase Agreements (PPAs): Following the 800 MW award in the first 83C competition and subsequent negotiations with the Commonwealth’s electric distribution companies, executed Power Purchase Agreements2 were filed with the Department of Public Utilities (DPU) on July 31, 2018. On August 1, 2018, the Massachusetts Department of Energy Resources (DOER) filed a letter with DPU. DOER stated that “the Vineyard Wind offshore generation long term contracts provide a highly cost-effective source of clean energy generation for Massachusetts customers.” The letter continued to state that total net benefits to Massachusetts ratepayers over the term of the contract would be approximately $1.4 billion. Finally, the DOER noted that the 800 MW Vineyard Wind Project provides a “unique opportunity to maximize the value of the federal investment tax credit (“ITC”) as the value of the credit is scheduled to be gradually reduced and will not be available for projects that start construction after December 31, 2019.”
The Power Purchase Agreements negotiated between Vineyard Wind and the Massachusetts electric distribution companies3 are currently under review by DPU. DPU issued the procedural notice and ground rules on September 6, 2018 and the briefing is due to be completed February 13, 2019; the review process is expected to conclude in March 2019.
Host Community Agreement with the Town of Barnstable: On October 3, 2018, the Company and the Town of Barnstable signed a Host Community Agreement (HCA) that reflects a shared belief that the Project can benefit the Town of Barnstable and that potential impacts to the Town of Barnstable can and will be minimized and/or appropriately mitigated. The product of many months of detailed discussions, the HCA reflects significant community support for the Project, for the Landfall Site at the Town-owned Covell’s Beach parking lot, and for ongoing cooperation between the Company and the Town of Barnstable. This cooperation was reinforced on October 18, 2018, when the Barnstable Town Council voted unanimously to grant Vineyard Wind an easement across Covell’s Beach and the adjacent parking lot. Vineyard Wind looks forward to continuing this productive and mutually beneficial relationship with town officials and residents alike. A continuing positive relationship with the Town of Barnstable, and the broader Cape community is key to the completion of a successful project that will benefit us all.
2 Power Purchase Agreements between Vineyard Wind and NSTAR Electric Company, Massachusetts Electric Company and Nantucket Electric Company, and Fitchburg Gas and Electric Light Company. 3 NSTAR Electric Company (d/b/a Eversource Energy), Massachusetts Electric Company and Nantucket Electric Company (d/b/a National Grid), and Fitchburg Gas and Electric Light Company (d/b/a Unitil).
Switch to Covell’s/Barnstable route: Based in significant part on the signing of the HCA, the Company now considers the Covell’s Beach route in Barnstable to be the preferred cable routing option. Use of the Covell’s Beach landfall reduces the length of the total offshore cable ro ute by approximately 4.5 miles. Horizontal Directional Drilling (HDD) staged from the Covell’s Beach parking lot (in the off season) will allow the Project to avoid any impacts to the beach and intertidal zone. The underground duct bank from the Landfall Site to the proposed substation is entirely in roadway layouts and about 0.7 miles shorter than the New Hampshire Avenue route. EFSB, MEPA, CCC and other agencies were advised of this change in the Company’s preference as quickly as possible following the signing of the HCA.
Completion of EFSB evidentiary hearings: Following an extensive discovery process, nine days of EFSB evidentiary hearings were held in October, with hearings finishing ahead of schedule on October 26. Legal briefs were submitted on November 28, followed by reply briefs on December 12. The EFSB staff expects to issue its Tentative Decision in March 2019, with a Final Decision anticipated in early April 2019.
New Bedford Marine Commerce Terminal lease signed: On October 22, 2018, Vineyard Wind signed an 18-month, $9 million lease for use of the 26-acre New Bedford Marine Commerce Terminal. Operated by the Massachusetts Clean Energy Center (MassCEC), the New Bedford Terminal was purpose-built to support construction of large-scale offshore wind projects.
MHI Vestas 9.5 MW Wind Turbine Selected: On November 27, 2018, Vineyard Wind announced that MHI Vestas Offshore Wind had been selected as the preferred supplier for the Project. MHI Vestas will supply the V164 9.5 MW offshore wind turbine for the Project, which is the largest wind turbine generator currently available and is extremely well suited to conditions along the eastern seaboard. Using this 9.5-MW wind turbine also adds important flexibility in the wind array layout and reduces the total area of the turbine array in federal waters.
BOEM Draft Environmental Impact Statement (DEIS): For the past year, the entire Vineyard Wind Project, including the offshore wind turbine generators, the inter array cables, the electrical service platforms, and offshore cables in federal waters has been undergoing a comprehensive NEPA review by the Department of the Interior’s Bureau of Offshore Energy Management (BOEM). This review has been conducted with the assistance of a number of federal agencies (e.g., USCG, Army Corps, US EPA, NMFS) as well as cooperating state agencies (e.g., MCZM, RI CRMC, RIDEM).
The DEIS, prepared by BOEM and independent third-party consultants to BOEM, was released on November 30, 2018. The purpose of the DEIS is to help BOEM determine whether to approve, approve with modifications, or disapprove the Construction and Operations Plan (COP) submitted by Vineyard Wind. Based on our review of the DEIS to date, we are pleased to find the review largely as anticipated, with no significant unexpected findings of project impacts identified. BOEM issued a Notice of Availability (NOA) in the Federal Register on December 7, 2018, opening a public comment period. In February 2019, BOEM will conduct public meetings in New Bedford, Barnstable (February 13), Nantucket, Martha’s Vineyard, and Rhode Island. Input received at the public meetings, together with written comment letters, will be used to inform preparation of the Final Environmental Impact
Statement (FEIS). The FEIS is expected to be completed in late April 2019 with the Record of Decision (ROD) anticipated in mid-July 2019.
Historic Agreement on Protections for North Atlantic Right Whales: On January 22, 2019, Vineyard Wind entered into an agreement with leading environmental organizations, Natural Resources Defense Council, the Conservation Law Foundation and the National Wildlife Fund, providing for enhanced protection measures for the North Atlantic Right Whale. The Right Whale being one of the most critically endangered marine mammals in our region, if not the world, we have gladly taken on a leadership role in collaborating with these leading environmental groups in developing enhanced protection measures.
Ongoing Project Refinements
As the environmental review progresses, the Company’s engineering team continues to analyze the 2018 marine survey data and is advancing the design and cable routing process. This work includes discussions with, and receipt of bids from, submarine cable providers and installation contractors. This additional information has been used to refine the cable installation approach and associated impact calculations. The specifics include:
More Capable Cable Installation Tool: As discussions with prospective cable installation contractors progress, the Company is able to consider cable installation tools with greater achievable burial depths (i.e., which could be 2.5 m [8 feet] or more), the use of which could further minimize sand wave dredging.
Generally Reduced Sand Wave Dredging Volumes: The use of a more capable cable installation tool coupled with additional analysis of the 2018 survey data have allowed the Company to refine its estimates for dredge volume in sand wave areas.
Reduced Area of Temporary Anchoring Impact: As discussions with prospective cable installation contractors progress, the estimated anchoring footprint has been reduced. Given the possibility of using a cable installation tool with a greater achievable burial depth, it is possible that anchoring will be needed along the entire cable route to achieve the necessary pulling force. However, the Company’s engineers have increased the spacing of each anchor set (from 200 m to 400 m) have reduced the number of anchoring points from 8 to 5 (four position anchors, one kedge or pulling anchor). In combination, these changes will reduce the area of temporary anchor impacts from 3.7 acres to approximately 2.1 – 2.3 acres (state waters only).
Reduced Area of Offshore Cable Protection/Armoring: It remains the Company’s clear priority to bury the offshore export cables to sufficient depths for the entire length of the cable, thus reducing or even eliminating the need for cable protection. However, at this point in the design process, the Company is maintaining a conservative assumption that up to 10% of the cables may require protection. At the same time, however, the Company’s engineers have been able to reduce the width of any cable protection from 9 m (~30 feet) to 3 m (~10 feet). This refinement allows the extent of armoring to be reduced from 27 acres to 9 acres (state waters only).
Regional Greenhouse Gas Reductions
As I hope this letter coveys, the Vineyard Wind team is working hard to ensure that the Project can be fully permitted by the Summer of 2019, thus supporting our planned start of onshore construction in late 2019. This will allow clean offshore wind energy to begin to flow to the grid by mid-2021, with full Project operations by early 2022. Once in full operation, the utility scale Vineyard Wind project will provide 800 MW of clean renewable energy while resulting in an estimated 1,680,000 tons-per- year of CO2 emissions reductions across New England. We all understand the importance of greenhouse gas reduction at this scale to the Cape and other exposed coastal areas. This understanding was emphasized when Mr. Andrew Gottlieb, Executive Director of the Association to Preserve Cape Cod, announced APCC’s endorsement of the Vineyard Wind project in December of 2018 (https://www.capecodtimes.com/news/20181219/apcc-announces-support-for-vineyard- wind-project).
We look forward to working with the Cape Cod Commission to maximize the benefits of this unique, timely, and important opportunity to establish the south coast of Massachusetts as the center for the offshore wind industry in the United States. We appreciate the opportunity for a hearing on our application at your earliest convenience.
Sincerely,
Erich Stephens, Chief Development Officer Vineyard Wind, LLC
Enclosures
cc: Circulation List Kristy Senatori, Cape Cod Commission, Executive Director Rachel Pachter, Vineyard Wind, VP Permitting Affairs Nate Mayo, Vineyard Wind, Manager, Development and policy Holly Carlson Johnston, Epsilon Associates, Project Manager Kate McEneaney, Epsilon Associates, Senior Consultant
DEVELOPMENT OF REGIONAL IMPACT
Vineyard Wind Connector
Submitted to:
CAPE COD COMMISSION 3225 Main Street Barnstable, MA 02630
Submitted by:
VINEYARD WIND LLC 700 Pleasant Street, Suite 510 New Bedford, MA 02740
Prepared by: In Association with:
EPSILON ASSOCIATES, INC. Foley Hoag LLP 3 Mill & Main Place, Suite 250 Stantec, Inc. Maynard, MA 01754 Geo SubSea LLC
February 8, 2019 Table of Contents
Table of Contents
1.0 INTRODUCTION/APPLICATION COVER SHEET 1-1 1.1 Consistency with Regional Policy Plan Goals 1-4 1.1.1 Natural Systems 1-4 1.1.2 Built Systems 1-7 1.1.3 Community Systems 1-11
2.0 PROJECT DESCRIPTION 2-1 2.1 Introduction 2-1 2.2 Offshore Transmission and Landfall Site Transition 2-2 2.2.1 Cable Type 2-2 2.2.2 Offshore Export Cable Corridor 2-2 2.2.3 Transition from Offshore to Onshore 2-4 2.3 Onshore Transmission 2-4 2.3.1 Cable Type and Duct Bank 2-4 2.3.2 Proposed Onshore Routes 2-6 2.4 Proposed Onshore Substation 2-7 2.4.1 Site 2-7 2.4.2 Proposed Equipment and Layout 2-8 2.4.3 Containment System and Dielectric Fluids 2-9 2.4.4 Stormwater Management 2-10 2.4.5 Sulfur Hexafluoride (SF6) 2-12 2.4.6 Substation Noise 2-12 2.5 Benefits 2-12 2.5.1 Energy Reliability Benefits 2-15 2.5.2 Economic Benefits 2-16 2.5.2.1 Offshore Wind Industry Accelerator Fund ($10 million) 2-20 2.5.2.2 Windward Workforce ($2 million) 2-20 2.5.2.3 Wind and Whales Fund ($3 million) 2-22 2.5.3 Environmental Benefits 2-23 2.6 Project Schedule 2-24 2.7 Permitting and Regulatory Approvals 2-25 2.8 Outreach and Prior Public and Agency Input 2-28 2.8.1 Agency, Municipal and Advocacy Group Outreach 2-28 2.8.2 Resident and Abutter Outreach 2-31 2.9 Consideration of Alternatives 2-33
4771.03/Vineyard Wind Connector i Table of Contents DRI Application Narrative Epsilon Associates, Inc. Table of Contents (Continued)
3.0 CONSTRUCTION METHODOLOGY 3-1 3.1 Offshore Cable Installation 3-1 3.1.1 Installation Technique 3-1 3.1.2 Sand Waves and Potential Dredging 3-5 3.1.3 Anchoring 3-6 3.1.4 Post-Installation Survey 3-7 3.1.5 Cable Protection 3-8 3.2 Transition from Offshore to Onshore 3-9 3.3 Onshore Duct Bank Construction and Cable Installation 3-10 3.3.1 Duct Bank Sequence and Timing 3-12 3.3.2 Environmental Inspector 3-13 3.3.3 Soil Management 3-13 3.3.4 Air Quality 3-14 3.3.5 Construction Noise 3-15 3.3.6 Solid Waste Management 3-16 3.3.7 Restoration 3-16 3.3.8 Onshore Cable Installation and Testing 3-17 3.4 Substation Civil Works and Construction 3-17 3.5 Laydown and Staging 3-19 3.6 Construction Equipment and Refueling 3-19 3.7 Conclusion 3-19
4.0 RESOURCE AREA IMPACTS AND MITIGATION 4-1 4.1 Introduction 4-1 4.2 Water Resources 4-1 4.2.1 Onshore Cable Route 4-1 4.2.2 Proposed Substation 4-2 4.2.2.1 Aquifer Protection 4-2 4.2.2.2 Stormwater Management 4-2 4.2.3 Construction-Period Water Resource Management and Mitigation 4-3 4.2.3.1 Dewatering 4-3 4.2.3.2 Refueling 4-3 4.2.3.3 Erosion and Sediment Control 4-5 4.3 Wildlife and Plant Habitat 4-7 4.3.1 Rare Species 4-7 4.3.1.1 Offshore Impacts and Mitigation 4-8 4.3.1.2 Onshore Impacts and Mitigation 4-8 4.3.2 Wildlife and Plant Habitat 4-9
4771.03/Vineyard Wind Connector ii Table of Contents DRI Application Narrative Epsilon Associates, Inc. Table of Contents (Continued)
4.4 Onshore Wetlands and Coastal Resources 4-10 4.4.1 Wetlands 4-10 4.4.2 Floodplain 4-10 4.4.3 Sea Level Rise 4-11 4.4.4 Shoreline Change 4-12 4.5 Marine Resources 4-12 4.5.1 Offshore Cable Installation Impacts 4-12 4.5.1.1 Sand Wave Dredging 4-14 4.5.1.2 Anchoring 4-14 4.5.1.3 Cable Protection 4-15 4.5.2 Marine Mammals 4-15 4.5.3 Fisheries, Fish Habitat 4-17 4.5.3.1 Affected Environment 4-17 4.5.3.2 Turbidity 4-18 4.5.3.3 Fisheries Communication Plan 4-19 4.5.3.4 Pre- and Post-Construction Fisheries Monitoring Plan 4-20 4.5.3.5 Mitigation 4-21 4.5.4 Time of Year Restrictions 4-22 4.6 Open Space and Recreation 4-24 4.7 Transportation 4-25 4.7.1 Onshore Transportation Management 4-25 4.7.2 Marine Navigation and Transportation 4-31 4.8 Economic Development 4-32 4.9 Heritage Preservation 4-32 4.9.1 Onshore Activities 4-32 4.9.2 Offshore Activities 4-33 4.10 Community Character 4-34
5.0 CONSISTENCY WITH REGIONAL POLICY PLAN 5-1 5.1 Land Use 5-1 5.1.1 Goal LU1 – Compact Growth and Resource Protection 5-1 5.1.2 Goal LU2 – Capital Facilities and Infrastructure 5-2 5.1.3 Goal LU3 – Rural Lands 5-3 5.2 Economic Development 5-3 5.2.1 Goal ED1 – Low-impact and Compatible Development 5-3 5.2.2 Goal ED2 – A Balanced Economy 5-5 5.2.3 Goal ED3 – Regional Income Growth 5-6 5.2.4 Goal ED4 – Infrastructure Capacity 5-7 5.3 Water Resources 5-8 5.3.1 Goal WR1 – General Aquifer Protection 5-8 5.3.2 Goal WR2 – Drinking Water Quality and Quantity 5-10
4771.03/Vineyard Wind Connector iii Table of Contents DRI Application Narrative Epsilon Associates, Inc. Table of Contents (Continued)
5.3.3 Goal WR3 – Marine Water Embayments and Estuaries 5-12 5.3.4 Goal WR4 – Freshwater Ponds and Lakes 5-13 5.3.5 Goal WR5 – Water Quality Improvement Areas 5-14 5.3.6 Goal WR6 – Public and Private Wastewater Treatment Facilities 5-16 5.3.7 Goal WR7 – Stormwater Quality 5-16 5.4 Coastal Resources 5-21 5.4.1 Goal CR1 – Maritime Industry, Character, and Public Access 5-21 5.4.2 Goal CR2 – Coastal Hazard Mitigation 5-23 5.4.3 Goal CR3 – Coastal Water Quality and Habitat 5-26 5.5 Marine Resources 5-33 5.5.1 Goal MR1 – Offshore Sand Mining and Conduits 5-33 5.6 Wetlands 5-47 5.6.1 Goal WET1 – Wetlands Protection 5-47 5.7 Wildlife and Plant Habitat 5-49 5.7.1 Goal WPH1 – Prevent Loss, Minimize Adverse Impact, and Maintain Diversity 5-49 5.8 Open Space Protection and Recreation 5-51 5.8.1 Goal OS1 – Open Space and Natural Resources 5-51 5.9 Transportation 5-55 5.10 Waste Management 5-56 5.10.1 Goal WM1 – Hazardous Materials and Waste 5-56 5.10.2 Goal WM2 – Solid Waste 5-59 5.11 Energy 5-60 5.12 Affordable Housing 5-62 5.13 Heritage Preservation/Community Character 5-62 5.13.1 Goal HPCC1 – Historic, Cultural, and Archaeological Resources 5-62 5.13.2 Goal HPCC2 – Community Character/Site and Building Design 5-63 5.14 Conclusion 5-67
4771.03/Vineyard Wind Connector iv Table of Contents DRI Application Narrative Epsilon Associates, Inc. List of Attachments
Attachment A Figures
Figure 1-1 Vineyard Wind Overview Figure 1-2 Barnstable County Project Overview Figure 1-3 Onshore Export Cable Routing
Figure 2-1 Offshore Export Cable Corridor Figure 2-2 Offshore Export Cable Corridor with State-Mapped and Vineyard Wind-Surveyed SSU Areas Figure 2-3 Offshore Export Cable Corridor – Potential Dredging Locations (Maximum Design Scenario) Figure 2-4 Typical Duct Bank Cross Sections Figure 2-5 Covell's Beach Route Environmental Constraints (3 Sheets) Figure 2-6 Proposed Substation Site Figure 2-7 Substation Draft Site Plan Figure 2-8 Proposed Substation Layout Figure 2-9 Proposed Substation – Surrounding Uses and Visual Screening Figure 2-10 Substation Rendering (7 Sheets) Figure 2-11 Onshore Routing and Variants
Figure 3-1 Jet Plow Figure 3-2 Typical Offshore Export Cable Spacing Figure 3-3 Covell’s Beach HDD Schematic Figure 3-4 Site Photo of Covell’s Beach Figure 3-5 Onshore Export Cable Installation
Figure 4-1 Mapped Water Resource Protection Areas, Covell’s Beach Route (3 Sheets) Figure 4-2 Covell’s Beach NHESP Mapping Figure 4-3 Wetland Resource Areas – Covell’s Beach Route (3 Sheets) Figure 4-4 FEMA Flood Zones, Covell’s Beach Route Figure 4-5 Vulnerability to Sea Level Rise, 1 Foot and 3 Foot Figure 4-6 Vulnerability to Hurricane Inundation Figure 4-7 Covell's Beach Shoreline Change Figure 4-8 Covell’s Beach HHD Plan and Profile Figure 4-9 Potential Areas for Anchoring Figure 4-10 Offshore Export Cable Corridor – Shellfish Suitability Areas Figure 4-11 Historic Resources, Covell's Beach Route Figure 4-12 Onshore Routing Shown on CCC Land Use Vision Map
Figure 5-1 Onshore Routing Shown on CCC’s Water Resources Classification Map II Figure 5-2 Onshore Routing Shown on CCC’s Water Resources Classification Map I Figure 5-3 Water Quality Improvement Areas as defined from CCC’s Water Resources Classification Maps I and II Figure 5-4 Onshore Routing Shown on CCC Significant Natural Resource Area Map
4771.03/Vineyard Wind Connector v Table of Contents DRI Application Narrative Epsilon Associates, Inc. List of Attachments (Continued)
Attachment B Attachment 1 to the Cover Sheet
Attachment C Host Community Agreement
Attachment D Massachusetts Environmental Policy Act (MEPA) Certificates
Attachment E Upland Cable Alignment Plans
Attachment F Abutters List
Attachment G DRI Circulation List
Attachment H Stormwater Management Report
Attachment I Fisheries Communication Plan
Attachment J Benthic Habitat Monitoring Plan
Attachment K Natural Resource Inventory
Attachment L Outreach and Consultation Overview
Attachment M Vineyard Wind – NGO Letter of Agreement January 22, 2019
List of Tables
Table 2-1 Duct Bank and Trench Dimensions (feet) 2-5 Table 2-2 Stormwater Drainage Conditions at the Proposed Substation Site 2-11 Table 2-3 Avoided Air Emissions in New England 2-24 Table 2-4 Environmental Permits, Reviews, and Approvals for the Preferred Project Route 2-25
Table 3-1 Duct Bank and Trench Dimensions (feet) 3-11
Table 4-1 Temporary Wetland Impacts along the Covell’s Beach Route. 4-10 Table 4-2 Offshore Export Cable Corridor Characteristics and Impacts from Installation of 2 Offshore Export Cables (Barnstable County waters) 4-13 Table 4-3 TMP mitigation measures along the Covell’s Beach Route 4-27
4771.03/Vineyard Wind Connector vi Table of Contents DRI Application Narrative Epsilon Associates, Inc. Section 1.0
Introduction/Application Cover Sheet
1.0 INTRODUCTION/APPLICATION COVER SHEET
1.1 Introduction
Vineyard Wind LLC (Vineyard Wind, the Company or the Proponent) is in the process of developing and permitting the Vineyard Wind Project, an offshore wind project with a nameplate generating capacity of approximately 800 megawatts (MW); the Vineyard Wind Connector is the portion of the larger Vineyard Wind Project that is located within Commonwealth of Massachusetts jurisdiction (i.e., portions of the offshore export cables within state waters, onshore duct bank and associated onshore export cables, and the proposed onshore substation). The Company is filing this Development of Regional Impact (DRI) application with the Cape Cod Commission (CCC) for the portions of the Vineyard Wind Connector that are located in Barnstable County, namely portions of the offshore export cables located within Barnstable County waters, the onshore duct bank and associated onshore export cables, and the proposed onshore substation. Throughout this application, the term “Project” refers to those components of the Vineyard Wind Project and Vineyard Wind Connector within Barnstable County and subject to the jurisdiction of the CCC. The Project includes offshore export cables, onshore export cables, and a proposed onshore substation. All of the Project elements located in Barnstable County are located in the Town of Barnstable.
Under Section 2(d)(i) of the CCC “Enabling Regulations Governing Review of Developments of Regional Impact” (Regulations), the Project is deemed a DRI because an Environmental Impact Report (EIR) is required to be prepared under the provisions of the Massachusetts Environmental Policy Act (MEPA). In addition, because the Project concerns a proposed energy related facility over which the Massachusetts Energy Facilities Siting Board (EFSB) has jurisdiction, it is subject to the procedural requirements in Section 7(d) of the Regulations to the extent applicable.
The Vineyard Wind Project will represent a major source of clean, renewable, cost-competitive energy for over 400,000 homes and businesses across the region, while reducing carbon emissions by over 1.6 million tons per year - the equivalent of removing approximately 325,000 automobiles from the road. Major elements of the Vineyard Wind Project include generation (the wind turbine area, located offshore in federal waters managed by the Bureau of Ocean Energy Management (BOEM)), transmission (offshore and onshore export cables connecting the wind turbine array to the existing grid, some of which are located in the Town of Barnstable), and grid interconnection (a new substation to be located in the Town of Barnstable). An overview map of the Vineyard Wind Project is provided as Figure 1-1.
The wind array is proposed on lands within the Massachusetts Wind Energy Area, an area on the continental shelf over 27 miles from the nearest land on Cape Cod at the Woods Hole Nobska Lighthouse. This area was established by the Federal BOEM as suitable for the development of such projects by a public process that included a stakeholder task force and a period of six years of study, refinement, environmental assessment, public comment and consideration.
4771/.03Vineyard Wind Connector 1-1 Introduction/Application Cover Sheet DRI Application Narrative Epsilon Associates, Inc. With the federal framework for the Wind Development Area in place, the Commonwealth of Massachusetts then enacted legislation to create structure for the wind energy market. Legislation requires the state’s investor-owned utilities (NSTAR, National Grid and Unitil) to award long-term agreements to enable project developers to finance and construct offshore wind projects. Pursuant to these requirements, on May 23, 2018, the Massachusetts Department of Energy Resources (DOER) and the utilities selected Vineyard Wind to construct its 800-MW offshore wind project.
Over this time period, Vineyard Wind progressed its design, permitting and outreach effort. Since 2011, Vineyard Wind has held numerous meetings with federal, state, and local agencies and a broad range of stakeholder groups including on Cape Cod. A comprehensive review of the entire Vineyard Wind project in state and federal waters, including a National Environmental Policy Act (NEPA) Environmental Impact Statement (EIS), is being conducted by the Department of the Interior’s BOEM. The Draft Environmental Impact Statement (DEIS) was released on December 7, 2018. BOEM has scheduled a series of public meetings on the DEIS in February of 2019.
In addition, a comprehensive review of the elements of the Vineyard Wind Project that are within state jurisdiction, including the portions located in Cape Cod, is being conducted by the Massachusetts Energy Facilities Siting Board (EFSB), Massachusetts Environmental Policy Act (MEPA) Office, and other agencies. Nine days of EFSB evidentiary hearings were held during October of 2018; legal briefs were submitted on November 28, 2018, followed by reply briefs in December 2018. The Company expects EFSB to issue its Tentative Decision in March of 2019. The Company filed its Final Environmental Impact Report (FEIR) with the MEPA Office on December 17, 2018 and expects the MEPA process to conclude on or about February 1, 2019.
In addition to the Cape Cod Commission, the Vineyard Wind Project is subject to public review and consultations by nearly 30 federal, tribal, state and local approval agencies, including the U.S. Army Corps of Engineers, National Marine Fisheries Service, the Massachusetts Department of Environmental Protection (DEP) and Coastal Zone Management (CZM), and local conservation commissions. Vineyard Wind also continues to engage in active conversations with the Wampanoag tribes.
In October of 2018, Vineyard Wind finalized a Host Community Agreement (HCA) with the Town of Barnstable, where the upland cable and substation are proposed to be sited. The HCA requires Vineyard Wind to make annual payments to the Town of at least $1.534 million each year in combined property taxes and Host Community Payments. In addition to taxes, the pact guarantees a total Host Community Payment of $16 million, plus an additional $60,000 (adjusted for inflation annually) for each year the project is in operation beyond 25 years. Among other benefits, the HCA also provides opportunity for review of Vineyard Wind’s specifications for a new substation by the Town. Transformers and other electrical equipment at the substation will be underlain by full volume impervious containment systems. The HCA is provided as Attachment C. On October 18, 2018, after a unanimous vote, the Town of Barnstable granted the Company an easement for the proposed work, subject to obtaining legislative approval, and has voted to petition the legislature for that approval (see Attachment K to the FEIR).
4771/.03Vineyard Wind Connector 1-2 Introduction/Application Cover Sheet DRI Application Narrative Epsilon Associates, Inc. Vineyard Wind seeks Cape Cod Commission approval of the Project, i.e., those components of the Vineyard Wind Project located in Barnstable County, which are together considered a DRI under the Cape Cod Commission Act and implementing regulations. A map showing portions of the Project in Barnstable County is provided as Figure 1-2. It includes 6.9 miles of offshore export cable, 5.3 miles of onshore duct bank and export cables primarily proposed in public roadway layouts in the Town of Barnstable, and a new substation located in Independence Park, an industrial park in the Town of Barnstable. The onshore routing is shown on aerial mapping in Figure 1-3. The Project will not be located in any other town in Barnstable County.
With this Application, Vineyard Wind seeks to demonstrate that the benefits of the Project significantly exceed its impacts and that the Project is consistent with the Regional Policy Plan and local and regional planning requirements. This DRI Application is structured as follows:
♦ The remainder of this section provides the required Application Cover Sheet (Attachment B of this Application contains the “Attachment 1” to the Cover Sheet) and a brief description of consistency with RPP goals;
♦ Section 2.0 contains a detailed Project description;
♦ Section 3.0 contains a description of the Project’s construction methodology;
♦ Section 4.0 describes resource areas, potential impacts, and proposed mitigation; and
♦ Section 5.0 details the Project’s consistency with the Regional Policy Plan.
Additional information is provided in various attachments to this application as follows:
♦ Figures (Attachment A);
♦ Attachment 1 to the Cover Sheet (Attachment B);
♦ Barnstable Host Community Agreement (Attachment C);
♦ Massachusetts Environmental Policy Act (MEPA) Certificates (Attachment D);
♦ Engineering Plans (Attachment E);
♦ Abutters List (Attachment F);
♦ DRI Circulation List (Attachment G);
♦ Stormwater Management Report (Attachment H);
♦ Fisheries Communication Plan (Attachment I);
♦ Benthic Habitat Monitoring Plan (Attachment J);
4771/.03Vineyard Wind Connector 1-3 Introduction/Application Cover Sheet DRI Application Narrative Epsilon Associates, Inc. ♦ Natural Resource Inventory (Attachment K); and
♦ Outreach Overview (Attachment L).
The Proponent’s MEPA filings, specifically the Environmental Notification Form (ENF), the Draft Environmental Impact Report (DEIR), the Supplemental Draft Environmental Impact Report (SDEIR), and the Final Environmental Impact (FEIR) have previously been provided to the CCC, and the Proponent requests that they be considered part of the record for this proceeding. The Proponent will also provide the CCC with a copy of any part of the record of the EFSB proceeding should such information be deemed useful in the review of the DRI.
4771/.03Vineyard Wind Connector 1-4 Introduction/Application Cover Sheet DRI Application Narrative Epsilon Associates, Inc.
Section 2.0
Project Description
2.0 PROJECT DESCRIPTION
2.1 Introduction
Vineyard Wind is in the process of developing and permitting an offshore wind project with a nameplate generating capacity of approximately 800 megawatts (MW); transmission elements of this larger project that occur within state jurisdiction are collectively proposed as the Vineyard Wind Connector (the “Project”). Components of the Project located within Barnstable County include offshore export cables, onshore export cables, and a proposed onshore substation.
Electricity generated by the wind turbine array (which is located in federal waters about 27 miles from the nearest land within Barnstable County) will be transported to the existing land-based transmission system via two new 220 kV three-core AC offshore transmission cable systems (export cable systems) that will travel north from the Wind Development Area in federal waters, cross into state waters, and then pass through a pocket of federal waters again in Nantucket Sound before re-entering state waters in the Town of Barnstable, Barnstable County, and making landfall on the Cape Cod mainland. The offshore export cables are described in greater detail in Section 2.2 below.
The two offshore export cables will transition to onshore export cables at landfall in a Town-owned parking lot at Covell’s Beach in the Town of Barnstable. Each three-core offshore export cable will transition to three separate single-core cables, each of which will be installed within its own separate conduit contained within a single concrete duct bank. The duct bank is proposed to be sited underground along existing public roadway layouts, ultimately terminating at the Proponent’s proposed substation off Independence Drive in Barnstable. The upland transmission cables are described in greater detail in Section 2.3 below.
At the proposed substation, voltage will step down from 220 kV to 115 kV in preparation for interconnection with the existing transmission system. The Project’s onshore substation is located within the Independence Park commercial/industrial area in Barnstable. It consists of approximately 6.3 acres of mostly wooded land, but also includes some existing parking areas and a small building. The small building was formerly associated with a larger structure on the western portion of the parcel, which once served as the distribution headquarters for the Cape Cod Times. The portion of the parcel that will be leased for the substation site is bordered to the north by the Barnstable Switching Station, to the west by the former Cape Cod Times building, to the south by Independence Drive, and to the east by an existing utility corridor. No wetlands or rare species habitat are present on the site. The proposed substation is described in Section 2.4 below.
4771.03/Vineyard Wind Connector 2-1 Project Description DRI Application Narrative Epsilon Associates, Inc. 2.2 Offshore Transmission and Landfall Site Transition
As described in greater detail in Section 2.2.2, the Project involves two offshore export cables within a single 810- to 1,000-meter-wide (2,660- to 3,280-foot-wide) Offshore Export Cable Corridor. Within the corridor, the two export cables will be installed with sufficient separation (typically approximately 100 meters) to allow for safe installation and any future repair work, if required. The offshore export cables will traverse approximately 6.9 miles of state waters within Barnstable County, and hence within Cape Cod Commission jurisdiction (see Figure 2-1). The width of the installation corridor provides flexibility to avoid and minimize impacts within the surveyed area, however, note the actual footprint of disturbance will be a fraction of this area. The direct trenching disturbance for each of the two offshore export cables will be approximately 3.3 feet (1 meter) wide (see Section 4.5.1).
The target burial depth for the offshore export cables will be up to approximately 5 to 8 feet (1.5 to 2.5 meters). The Proponent anticipates that most of the offshore export cable will be installed using simultaneous lay-and-bury via jet-plow, although other methods (e.g., mechanical plow, mechanical trenching) may be required in areas of hard bottom or other challenging conditions.
2.2.1 Cable Type
Each offshore export cable will be comprised of a three-core 220 kV AC cable for power transmission and fiber optic cable for communication, temperature measurement, and protection of the high-voltage system. Each 220-kV armored offshore cable would be approximately 10 inches (25.5 centimeters) in diameter with a weight of approximately 64 pounds per linear foot (95 kilograms per meter), and will include three copper or aluminum conductors, with each conductor encapsulated by solid cross-linked polyethylene (XLPE) insulation. Water-blocking sheathing will be used to prevent water infiltration. The three insulated conductors will be twisted with synthetic filler between the conductors, and the twisted or bundled conductors will then be wrapped in wire armoring and finally encased in a tough outer sheath. This AC offshore cable system will not contain any fluids, and has been used extensively on European offshore wind projects.
2.2.2 Offshore Export Cable Corridor
Results from Vineyard Wind’s 2017 marine surveys were used to distill a wide range of offshore route alternatives into a Western Offshore Export Cable Corridor and an Eastern Offshore Export Cable Corridor. Results from marine surveys performed in spring 2018 led the Proponent to select the Western Offshore Export Cable Corridor as the proposed offshore route, thus eliminating the Eastern Offshore Export Cable Corridor from the Project; this selection was addressed in detail in the Massachusetts Environmental Policy Act (MEPA) environmental review process (Section 3 of the Draft Environmental Impact Report (DEIR)
4771.03/Vineyard Wind Connector 2-2 Project Description DRI Application Narrative Epsilon Associates, Inc. and Section 2 of the Supplemental Draft Environmental Impact Report (SDEIR)), and reflected selection of the shorter offshore route with fewer environmental impacts that was also confirmed as technically suitable for cable installation.
A number of technical and environmental considerations and constraints have factored into the delineation of the proposed Offshore Export Cable Corridor, including:
♦ The corridor should avoid or minimize impacts to Special, Sensitive and Unique (SSU) areas, including North Atlantic Right Whale Habitat, hard/complex bottom, and eelgrass;
♦ Water depths greater than 20 feet (6 meters) are preferable accommodating the cable-laying vessels that are likely to be utilized for this Project;
♦ Minimizing cable length minimizes subsurface disturbance and transmission losses;
♦ The route should not turn more than 30 degrees at a time, with a minimum turn radius of 165 feet (50 meters);
♦ The route should be perpendicular, or nearly perpendicular, to any large seabed slopes, and likewise across any existing offshore cables; and
♦ Anchorage areas and areas with mapped shipwrecks and boulders are to be avoided or minimized.
The offshore cable corridor within Cape Cod Commission jurisdiction is shown on Figure 2- 1. The total length of the corridor within Barnstable County is 6.9 miles. No core habitat for whales is present in the area, and the corridor will avoid most hard/complex bottom habitat mapped in the Massachusetts Ocean Management Plan (OMP). See Figure 2-2. The Company’s 2018 marine surveys have been used to refine the OMP mapping of hard bottom and complex bottom based on higher-resolution survey data. The results are depicted on Figure 2-2. As can be seen in Figure 2-2, the corridor avoids hard bottom and encounters one section of complex seafloor close to outer limits of jurisdiction, near federal waters.
Some areas of Nantucket Sound have active sand waves that can exceed 12 feet in height. Marine survey work in summer 2017 and again in spring/summer 2018 allowed the Proponent to assess these areas, which may require some pre-cable-laying dredging to ensure that sufficient burial depth can be achieved and maintained; a number of possible dredging techniques are under consideration (see Section 3.1.2). As shown on Figure 2-3, the stretch of potential discontinuous dredging of the tops of sand waves within Barnstable County is limited to an approximately 0.8-mile length of the Offshore Export Cable Corridor; as described in Section 3.1.2, the actual length of sand wave dredging (given it will be a discontinuous activity used to remove only the tops of sand waves) within
4771.03/Vineyard Wind Connector 2-3 Project Description DRI Application Narrative Epsilon Associates, Inc. Barnstable County waters is estimated to be approximately 650 feet (200 m). It is important to note that since sand waves are mobile features with shifting morphology, this length of dredging is an estimate at this particular time.
2.2.3 Transition from Offshore to Onshore
Horizontal Directional Drill (HDD) is proposed at the Covell’s Beach Landfall Site in Barnstable. The HDD will enable the Project to avoid impacts to the Coastal Beach and nearshore areas. The physical connection between the offshore and onshore export cables will be made in one or more onshore underground concrete transition vaults, accessed via manholes covered by secure metal covers. The only components of the cable system that will be visible from aboveground will be manhole covers. The necessary work at the Landfall Site would be performed in the off-season (avoiding the period from Memorial Day to Labor Day), or as otherwise permitted by the relevant agencies and Town of Barnstable officials, to minimize any disturbance to residents and visitors. The HDD is described in further detail in Section 3.2.
2.3 Onshore Transmission
For the onshore stretch of transmission, each three-core (three-conductor) offshore export cable will transition to three separate single-core 220 kV cables consisting of a copper or aluminum conductor covered by solid cross-linked polyethylene (XLPE) insulation and separate fiber optic cables that will be installed from the Landfall Site to the onshore substation; this transition will occur at the transition vaults proposed at the Landfall Sites. Therefore, since the Project will consist of two offshore export cables (each with three cores), it will contain six onshore export cables and a minimum of two fiber optic cables.
2.3.1 Cable Type and Duct Bank
Each onshore cable will be comprised of a single core (copper or aluminum) encapsulated by a triple-extruded and dry-cured XLPE solid insulation. A metallic sheath and a non- metallic outer jacket will wrap around this layer. These last layers have the main function to avoid the direct contact of the conductor to the ground, and to control and minimize thermal and electrical losses. The diameter of each onshore cable is approximately 6 inches (15 cm), and the cable will weigh approximately 16.4 pounds per foot (24.4 kg/m); the cables will not contain any fluids. Three of these cables will make up a single 220 kV AC circuit.
Each of the six onshore export cables will have its own conduit within a concrete duct bank that will be installed along the entire length of the onshore cable route. This duct bank, shown in a typical cross-section on Figure 2-4, will be an array of PVC pipes or sleeves encased in concrete. Up to eight approximately 10-inch-diameter conduits spaced
4771.03/Vineyard Wind Connector 2-4 Project Description DRI Application Narrative Epsilon Associates, Inc. approximately 12 inches apart will be installed within the duct bank to accommodate onshore conductors and spare conduits, with additional smaller conduits for fiber optic communications cables; grounding will be accommodated within the duct bank trench.
The majority (approximately 18,900 feet) of the Covell’s Beach route, will be arrayed two conduits wide by four conduits deep, with the total duct bank measuring 2.5 feet wide and five feet deep. For the remaining approximately 8,500 feet of the Covell’s Beach route, the array will be four conduits wide by two conduits deep, with the total duct bank measuring 5 feet wide and 2.5 feet deep (see Table 2-1). This “flat” array will be utilized at the start of the route where depth to groundwater is less, and within other areas where utility crossings may benefit from such an array.
Table 2-1 Duct Bank and Trench Dimensions (feet)
Duct Bank Trench Conduit Width at Width at Top Width at Top Width Depth Depth Layout Bottom (0.3 side slope) (0.5 side slope) 4x2 5 2.5 5.5 5.5 8.8 11 (flat) 2x4 2.5 5 8 3 7.8 11 (upright)
The duct bank layout, and hence the excavated trench dimensions, will vary as described in Table 2-1. In general, the width at the top of the trench will vary between approximately 8 and 11 feet, and will be supported by temporary trench boxes or other shoring as appropriate.
The target depth of cover in all cases will be at least three feet, although if required in some instances (e.g., at certain utility crossings), the minimum cover will be 2.5 feet. The typical duct bank layout as shown in Figure 2-4 may be modified in areas where dictated by existing conditions, such as the presence of culverts. If an existing culvert is not deep enough to allow a duct bank section to be installed above, then the duct bank will be installed beneath the culvert while providing sufficient support.
Once the duct bank is in place, the cables (one cable per conduit) will be pulled into place from underground vaults, which will be spaced at intervals of approximately 1,500 to 3,000 feet, depending on route characteristics. Similar XLPE cable systems have been installed by Massachusetts utilities in several urban and suburban locations in recent years. Installation of the in-road underground duct bank and export cables within public roadways will be performed during the off-season, or as otherwise permitted by the relevant agency or Town of Barnstable departments, to minimize traffic disruption. This type of construction typically advances at the rate of 100 to 200 feet per day.
4771.03/Vineyard Wind Connector 2-5 Project Description DRI Application Narrative Epsilon Associates, Inc. Once the proposed duct bank and associated onshore export cables arrive at the proposed substation site (described in Section 2.4), the voltage will step down from 220 kV to 115 kV. From the proposed substation, 115-kV onshore underground export cables will continue for approximately 0.1 miles to the Barnstable Switching Station, where they will interconnect with the existing transmission grid.
2.3.2 Proposed Onshore Routes
The Covell’s Beach route begins at a large paved parking area associated with Covell’s Beach, a residents-only public beach that is owned and managed by the Town of Barnstable, and follows existing roadway layouts to the proposed substation site off Independence Drive (see Figure 2-5).
The Covell’s Beach Routebegins at Covell’s Beach Landfall Site and proceeds easterly direction on Craigville Beach Road for 0.6 miles before turning north on Strawberry Hill Road, which it follows for 1.5 miles before merging with Wequaquet Lane north of Route 28. The route then continues northeasterly for 0.3 miles to Phinneys Lane, and follows that road before turning off onto Attucks Lane and then following Attucks Lane, Independence Drive, and Communication Way to the proposed Project substation. A 0.1-mile overland segment connects the proposed substation to the interconnection point at the existing Barnstable Switching Substation.
Land use along the Covell’s Beach Route is largely residential, but includes some areas of commercial development at the crossings of West Main Street and Route 28 in Hyannis. Land use along Attuck’s Lane and Independence Drive is commercial.
The total length of this route is 5.3 miles, all of which are within existing roadway layout.
Route Variant
The Proponent as also identified a route variation (Utility ROW Variation). This variation is being maintained through the engineering process in the event of engineering or other constraints arising that prohibit construction on the preferred route.
The Utility ROW Variation follows the preferred route up to the point where Phinneys Lane crosses Route 132. Instead of turing east on Attucks Lane, the Utility ROW Variation continues for a short distance on Phinneys Lane to an existing overhead utility ROW (Eversource ROW #346). The duct bank would be constructed underground on the Utility ROW Variation for 1.6 miles to the proposed Project substation. This section of Eversource ROW #346 contains existing 115 kV overhead lines and 25 kV overhead transmission lines. A short, 0.1-mile overland segment, which will also be constructed as underground duct bank, connects the proposed substation to the adjacent interconnection point at the existing Barnstable Switching Substation.
4771.03/Vineyard Wind Connector 2-6 Project Description DRI Application Narrative Epsilon Associates, Inc. The total length of this route is 5.4 miles, 3.8 of which are within existing roadway layout and 1.6 of which are within existing utility ROW.
The Proponent would be required to obtain rights from Eversource to utilize the section of the route along NSTAR’s ROW.
2.4 Proposed Onshore Substation
The Project will require an onshore substation where the power, delivered at 220 kV by the offshore and onshore export cables, will be “stepped down” to 115 kV before connecting to the existing 115-kV Barnstable Switching Station.
2.4.1 Site
The Project’s onshore substation site is located immediately south of Eversource’s existing 115kV Barnstable Switching Station, at the east end of Independence Park, an industrial/commercial park development.
More specifically, the Project’s new substation will be located on the eastern portion of an approximately 13.1-acre previously-developed parcel in Barnstable (see Figure 2-6). The Project’s substation site consists of approximately 6.35 acres of mostly wooded land, but also includes some existing parking areas and a small building. The small building was associated with a larger structure on the western portion of the larger parcel that once served as the distribution headquarters for the Cape Cod Times. The portion of the parcel that will be leased for the substation site is bordered to the north by the Barnstable Switching Station, to the west by the former Cape Cod Times building, to the south by Independence Drive, and to the east by an existing approximately 150- to 200-foot-wide electric transmission corridor with a number of 115 kV overhead lines on H-frame and single pole support structures. This transmission corridor, Eversource ROW #344, runs between the Barnstable Switching Station and the Hyannis Junction Station, approximately a half-mile to the south.
The proposed buried duct bank carrying the 220-kV transmission circuits will enter the Project substation site either from Independence Drive. Vehicular access to the substation will be from the west by an existing driveway that serves the former Cape Cod Times building at 40 Communication Way.
The Project’s onshore substation site is in the Barnstable Industrial (IND) zoning district, the Ground Water (GW) Protection Overlay District, and the Ground-Mounted Solar Photovoltaic Overlay District. A portion of the property is located in the Wellhead (WH) Protection Overlay district.
4771.03/Vineyard Wind Connector 2-7 Project Description DRI Application Narrative Epsilon Associates, Inc. 2.4.2 Proposed Equipment and Layout
The Project’s onshore substation will include two 220/115-kV “stepdown” transformers, other necessary equipment, switchgear, and bus work. A battery storage system may also be installed at the onshore substation. The substation will be a conventional “air insulated” (AIS) design or a Gas-Insulated Substation (GIS) design. In an AIS design, equipment spacing allows for ambient air to provide sufficient electrical insulation. The Proponent is also considering the use of a Gas-Insulated Substation (GIS) design, which uses sulfur hexafluoride (SF6) gas as an insulating medium. In this case, the GIS system which is more expensive than a conventional AIS design may be warranted, if determined the substation site and the available space within the Cape Cod Times building cannot accommodate the standard AIS design and supporting reactive power equipment while maintaining appropriate vegetative buffering at the perimeter of the station.
More specifically, the new substation will include two 450 megavolt-ampere (MVA)1 220/115 kV stepdown transformers, up to four separate iron core reactors for cable compensation and reactive support operating in conjunction with synchronous condensers, capacitive harmonic filters, and offsetting air core reactors together with the necessary circuit breakers, bus work, and lightning protection masts. Final reactive support and voltage control could be accomplished by two to four synchronous condensers or a variation of synchronous condensers and STATCOMs. Additional transformers may be required for connection of the synchronous condensers and reactive power supporting equipment. Based on the initial equipment models available at the commencement of the electrical studies and design, it was determined that the synchronous condensers would be necessary to meet grid compliance/performance for voltage/reactive support and address the inherently low short circuit ratio of the transmission system in this area. The synchronous condensers are anticipated to utilize a portion of the existing Cape Cod Times building on the unleased portion of the substation site. Some modifications may be necessary to the existing building to accommodate the installation. The synchronous condensers are physically similar to electric generators without a prime mover connected by dedicated transformers to the 115kV bus. If use of the existing building is deemed not feasible, then the synchronous condensers would be located in an enclosure on the substation site. Final equipment rating and quantities are subject to the ongoing ISO-NE interconnection studies and overall Project electrical design. The Proponent is also exploring the possible use of biodegradable dielectric fluid for use in the main power transformers.
The new substation will also include a small (approximately 1,200-square-foot) one-story control and protection enclosure or building.
1 Mega volt amperes, a standard measure of electrical load
4771.03/Vineyard Wind Connector 2-8 Project Description DRI Application Narrative Epsilon Associates, Inc. A site plan for the new substation is provided as Figure 2-7, and the substation layout is shown on Figure 2-8. As a general matter, the new substation will be similar in scale and appearance to the existing Barnstable Switching Station immediately to the north, albeit the Substation would not have any additional overhead transmission lines, is at a lower grade, and features significant deciduous vegetative screening and a sound and visual barrier.
As shown on Figure 2-7, the Proponent plans to retain at least a 50-foot-wide band of existing vegetation along the south side of the site (along Independence Drive) as well as a vegetated buffer at least 30 feet wide on the eastern side of the site (in locations where it would not conflict with the utility ROW); the latter, together with proposed noise barriers discussed in Section 2.4.6, will provide visual screening with respect to the Village Green apartments to the east. This four-building, 60-unit apartment development was constructed in 2014 on a formerly wooded parcel directly east of the existing Barnstable Switching Station and the adjoining ROW.2 Vegetation on the east side of the proposed Project substation site, together with existing vegetation on the adjoining utility ROW, will also provide screening for the new 29-unit apartment building under construction at the intersection of Independence Drive and Mary Dunn Road (see Figure 2-9). Topography will further reduce potential visual impacts from the proposed substation, as the site elevation is approximately 20 feet lower than the site elevation of the existing Barnstable Switching Station. Preliminary visual renderings are provided as Figure 2-10.
The substation yard area will be finished in crushed stone, and perimeter security fencing will be installed. Access to the new substation site will be via the existing paved driveway at the northwest corner of the former Cape Cod Times printing and distribution plant parcel. This is one of two driveways which serve the former printing plant, both of which are off Communications Way. The substation design also includes an all-weather internal access road.
2.4.3 Containment System and Dielectric Fluids
The substation design will include at least full volume (110%) impervious containment sumps for all equipment containing dielectric fluid (i.e., the main transformers, reactors, capacitor banks for the harmonics filter, and any equipment containing oil associated with the synchronous condensers and/or STATCOMs). While sumps for transformers are standard practice, they are not normally used for other lower-volume fluid-filled equipment given the low probability of any leakage. However, the Company has opted to commit to such containment at this time, given the sensitive nature of the Cape Cod watershed and based on consultations with local officials and comments at public meetings. In addition, at the Town of Barnstable’s request, Vineyard Wind has committed to adding additional containment volume in consideration of an extreme rain event. Thus, the Company has adjusted the 110% containment volume upwards to account for a simultaneous 100-year,
2 ROW #344, includes two 115 kV lines (#124, # 128) on wooden H frames and two 25 kV lines.
4771.03/Vineyard Wind Connector 2-9 Project Description DRI Application Narrative Epsilon Associates, Inc. 24-hour rainfall event, which on Cape Cod is conservatively established at 9 inches of rain. Also included in the design as additional mitigation is a common drain system that routes each individual containment area after passing through an oil inhibition device to an oil water separator before draining to the infiltration basin. Assuming a 31-foot by 43-foot containment sump footprint for one of the main step-down transformers, this would add approximately 7,500 gallons to the design containment volume. These measures are above and beyond industry best practices to ensure protection of the groundwater resource.
The Company will include spill response in its emergency response plan as part of the Project’s overall safety management system. Proper spill containment kits and spill control accessories will be strategically situated at the substation and will include absorbent pads, temporary berms, absorbent socks, drip pans, drain covers/plugs, appropriate neutralizers, over pack containers all for immediate use in the event of any inadvertent spills or leaks. All operators will be trained in the use and deployment of such spill prevention equipment. The Company will also have a third-party licensed spill response contractor on call as part of the Project’s overall Oil Spill Response Plan. The Company will work closely with Barnstable officials to develop an Emergency Response Plan.
Finally, Vineyard Wind is investigating the possible use of biodegradable dielectric fluid for the main transformers. The Company has engaged the major suppliers in discussion for the use of biodegradable dielectric fluid in components where feasibility and efficacy can be demonstrated. The initial response has been that the use of this type of dielectric fluid in the main transformers is likely possible, but confirmation of experience with transformers of this size (450MVA) still requires some validation. It would also be expected that the reactors could also utilize the biodegradable dielectric fluid. Vineyard Wind has not been able to confirm any experience with the use of this oil in the factory-sealed harmonic filter capacitors. It does not appear such a request has been made to the industry, since these factory-sealed components which contain relatively small quantities of dielectric fluid (e.g., 4-8 gallon/unit) do not have a history of failure. Regardless, the Company is confident that the containment and other safeguards planned for the Substation will protect groundwater, and municipal water supplies in particular, regardless of whether the dielectric fluid used is characterized as biodegradable. While Vineyard Wind will continue to investigate these options, it cannot guarantee that the technology will be available or practicable for the substation.
2.4.4 Stormwater Management
On the substation site, stormwater best management practices (BMPs) will primarily function to minimize potential adverse water quality impacts to groundwater and to downgradient receptors. The proposed BMPs will also maintain or reduce peak stormwater discharge rates released off-site, ensuring no erosive conditions will be generated; a storage/infiltration basin will be provided to ensure that post-development runoff volumes will not exceed pre-development runoff volumes.
4771.03/Vineyard Wind Connector 2-10 Project Description DRI Application Narrative Epsilon Associates, Inc. As described in Attachment H (Stormwater Report, which was also included as Attachment N of the SDEIR), the approach to stormwater management on the substation site will be to balance the needs of the Project while preserving the integrity of the groundwater aquifer and minimizing impacts to adjacent lands. To the extent feasible, environmentally-sensitive design and low-impact development (LID) measures will be incorporated into the planning and design of the Project. The proposed stormwater management system will incorporate BMPs, as described in the MassDEP Stormwater Management Policy Handbook and as recommended in the Town of Barnstable’s site plan criteria. In addition, given that the site is located within a Zone II water supply protection area for the Town of Barnstable, and to ensure the highest level of groundwater protection, it is the Company’s intention to provide full containment beneath any substation equipment containing transformer fluids (as described above).
The Stormwater Management Report included detailed HydroCAD® 1 calculations of the stormwater drainage conditions for the 2, 10 and 100-year frequency 24-hour storm events and current estimates of peak runoff rates and volumes for existing and proposed site conditions (see Table 2-2):
Table 2-2 Stormwater Drainage Conditions at the Proposed Substation Site
Total Runoff Summary Table Peak Runoff Rate (cfs)* Volume (af)** 2-year storm event Existing Conditions 0 0 Proposed Conditions 0 0 10-year storm event Existing Conditions 0 0 Proposed Conditions 0 0 100-year storm event Existing Conditions 0.34 0.06 Proposed Conditions 0.21 0.019 * flow rate, cfs = cubic feet per second ** volume, af = acre feet
In summary, the substation can be designed so post-development total discharge volumes and peak runoff rates will be less than the pre-development (existing) conditions for the 2- year, 10-year, and 100-year 24-hour storms. In addition, the proposed stormwater management design (described in Attachment H) will meet or exceed the Massachusetts Stormwater Policy recommendations for this Project, and the Project will comply with the MassDEP Stormwater Standards.
4771.03/Vineyard Wind Connector 2-11 Project Description DRI Application Narrative Epsilon Associates, Inc. 2.4.5 Sulfur Hexafluoride (SF6)
As described above, some of the electrical equipment at the proposed onshore substation will be hermetically sealed gas-insulated switchgear, which will contain SF6. SF6 is an inert, non-toxic, non-flammable, and odorless gas. SF6 is also an excellent electrical insulator. The combination of these properties makes it an excellent choice, and preferred industry practice, for safe and efficient operation of electrical equipment such as will be used at the Project’s substation.
SF6 gas will be used in circuit breakers at the Company’s proposed substation, which are designed to be gas-tight and sealed for the life of the equipment. SF6 quantities for such circuit breakers can vary between manufacturer, but the Company anticipates that the 115kV and 220kV AIS dead tank circuit breakers will contain between 125 and 165 pounds of SF6 gas per breaker. The current configuration of the proposed substation has between 14 and 16 AIS circuit breakers. The circuit breakers will be equipped with monitoring devices which will alarm on low SF6 gas pressure, which would be indicative of a leak and trigger an appropriate response to contain and mitigate any such leak. U.S. EPA has a well- developed regulatory program for control of SF6 use because of its potency as a greenhouse gas, and the equipment will meet the applicable state requirements of 310 CMR 7.72. The Project will be in full compliance with those programs.
2.4.6 Substation Noise
Sounds level modeling was conducted to assess the noise associated with substation equipment, most specifically proposed transformers and condensers, and noise mitigation features within the substation will be designed to mitigate noise impacts. The proposed substation will include noise control features to limit sound level impacts in the neighboring community primarily to the northeast and east. A low-noise design will be specified for the main transformers, and the synchronous condensers will be housed in a building or acoustically-treated equipment enclosure. In addition, the substation design includes a series of strategically-placed noise barriers. These barriers are conceptual in design, and noise control features for the Project will be advanced as the substation layout is refined. The current design calls for approximately 23,200 square feet of sound barrier walls or equivalent, with a height up to 30 feet. Once final substation design is complete, the noise modeling will be finalized and the design of the sound barrier system will be refined. Noise levels would meet all applicable regulatory standards, including absence of pure tone conditions.
2.5 Benefits
The purpose of the Project is to provide the Commonwealth of Massachusetts with 800 MW of clean, renewable wind energy. The Project is being developed in response to the 2016 energy legislation passed by the Massachusetts Legislature and signed by Governor Baker, and in response to evolving demand for offshore wind energy by other New England and
4771.03/Vineyard Wind Connector 2-12 Project Description DRI Application Narrative Epsilon Associates, Inc. northeastern states. Construction of the Project will serve the public interest by increasing the reliability and diversity of the regional and statewide energy supply while reducing greenhouse gas emissions from the regional power generation grid.
The Project is expected to create a range of environmental and economic benefits for southeastern Massachusetts (including Barnstable County), Massachusetts as a whole, and the entire New England region. Project benefits will extend across the design, environmental review, and permitting phase, the procurement, fabrication, and construction/commissioning phase, the multi-decade operating phase, as well as the future decommissioning effort.
Project benefits include, but are not limited to:
♦ Reduced costs for electricity customers in Massachusetts: Filings made at the Department of Public Utilities (DPU) on July 31, 2018, assert that the prices for output from Vineyard Wind’s offshore wind project will provide savings to ratepayers in addition to other benefits, with total net benefits that have been cited by the DOER at approximately $1.4 billion over the life of the contract.3 The Power Purchase Agreements negotiated between Vineyard Wind and the Massachusetts utilities4 are currently under review by DPU. DPU issued a procedural notice on September 6, 2018; the review process is expected to conclude in March 2019.
♦ Clean renewable energy at large scale and a high capacity factor: The location of the associated wind turbine generators (WTGs) well offshore in a favorable wind regime, coupled with the efficiency of the WTGs, will enable the Project to deliver substantial quantities of power on a reliable basis, including during times of peak grid demand.
♦ Reducing winter electricity price spikes: The Project adds high and stable winter capacity factor offshore wind generation to the region, increasing resources available to address electricity demand spikes, and reducing reliance on fossil fuel generation. The Project will therefore be unaffected by the risk of potential fossil fuel shortages and will help to alleviate price volatility. The Project could reduce
3 Petitions for approval of long-term contracts with Vineyard Wind were filed, with supporting documents, at the Department of Public Utilities and docketed as D.P.U. 18-76, D.P.U. 18-77, and D.P.U. 18-78. DOER filed a letter in each docket, which among other things, summarizes benefits to Massachusetts ratepayers. See https://eeaonline.eea.state.ma.us/EEA/FileService/FileService.Api/file/FileRoom/9676907.
4 NSTAR Electric, Massachusetts Electric and Nantucket Electric, and Fitchburg Gas and Electric Light Company.
4771.03/Vineyard Wind Connector 2-13 Project Description DRI Application Narrative Epsilon Associates, Inc. the need for the gas- and oil-burning Canal units 1 and 2 to run, especially during winter peak events when winds are high and conditions ideal for wind energy generation.
♦ Improving the reliability of the electric grid in Southeastern Massachusetts: The Project will connect to the bulk power system on Cape Cod, and thus will increase the supply of power to Barnstable County and other parts of southeastern Massachusetts, an area which has experienced significant recent (and planned) generation unit retirements. Because of its interconnect location and generation type, adding an additional 800 MW of offshore wind generation to the current power generation portfolio in Massachusetts will provide fuel diversification and enhance the overall reliability of power generation and transmission in the region and in particular the southeast Massachusetts (SEMA) area, which has seen, and will continue to see, substantial changes in generation capacity. This will mitigate future costs for ensuring reliable service for Massachusetts customers.
♦ Large reductions in emissions of greenhouse gases and other pollutants: The WTGs for the Project will be among the most efficient currently available for offshore use. It is expected that the WTGs will be capable of operating with an annual capacity factor in excess of 45%. For the 800-MW Project, machines of this efficiency and capability will reduce ISO NE CO2 emissions by approximately 1,630,000 tons per year (tpy). This is the equivalent of removing approximately 325,000 automobiles from the road. In addition, nitrogen oxides (NOx) emissions across the New England grid are expected to be reduced by approximately 1,050 tpy with SO2 emissions being reduced by approximately 860 tpy.
♦ Additional economic benefits for the region: Project construction will generate substantial economic benefits, including opportunities for regional maritime industries (tug charters, other vessel charters, dockage, fueling, inspection/repairs, provisioning).
♦ New employment opportunities: The UMass Dartmouth study prepared in support of the Section 83C bid showed that the Project will result in additional employment and economic development in Massachusetts, including supporting approximately 3,600 full-time equivalent jobs in Massachusetts over the life of the Project.
♦ Support for Massachusetts policies: The project will assist the Commonwealth in meeting its Global Warming Solutions Act (GWSA) goals and reducing the cost of compliance with the Renewable Energy Portfolio Standard (RPS) through increased Renewable Energy Credit (REC) supply.
4771.03/Vineyard Wind Connector 2-14 Project Description DRI Application Narrative Epsilon Associates, Inc. 2.5.1 Energy Reliability Benefits
The proposed Vineyard Wind Connector would enhance the reliability and diversity of the energy mix on Cape Cod and in the Commonwealth of Massachusetts. This is particularly important given that several base load/cycling plants have already retired or are slated for retirement, including:
♦ Brayton Point Power Plant (Somerset, MA): 1,600 MW, closed on May 31, 2017;
♦ Pilgrim Nuclear Power Plant (Plymouth, MA): 690 MW, to be closed by May 31, 2019;
♦ Vermont Yankee Nuclear Power Plant (Vernon, VT): 620 MW, shut down December 29, 2014;
♦ Montaup Power Plant (Somerset, MA): 174 MW, shut down in 2010; and
♦ Mt. Tom Station (Holyoke, MA): 136 MW, shut down in 2014.
In addition, other plants such as Canal Generating Station (1,200 MW, oil/natural gas-fired, two units commissioned in 1968 and 1976), located in Sandwich, are approaching their normal end of life, making it important for other energy generation alternatives to fill the gap. Along with the plants mentioned above, ISO-NE has identified over 5,000 MW of oil and coal capacity “at risk” for retirement in the coming years.5
Between the decommissioning of nuclear power plants at Pilgrim and Vermont Yankee, and in the 1990s closings of Yankee Rowe (185 MW) and Maine Yankee (900 MW), New England has lost or is about to lose a significant portion of its large “zero carbon” base load plants.
Lastly, Cape Cod is at the outer edge of the regional transmission system. The Cape is essentially supplied by one 345 kV and two 115 kV radial feeds. While recent significant investments in transmission reliability have strengthened the electricity supply to Cape Cod, Vineyard Wind would further improve reliability by feeding power into the center of the Cape transmission system. Connecting a substantial electricity supply to Cape Cod will mitigate future costs for ensuring reliable service to Massachusetts customers.
The Vineyard Wind project will be a major source of zero-carbon electric power. The 800- MW project can supply more than the peak load for all of Cape Cod when running at full capacity. As the offshore wind industry has developed, wind turbines have moved further offshore. When coupled with higher hub heights and longer, more efficient blades, the
5 ISO-NE. https://www.iso-ne.com/about/regional-electricity-outlook/grid-in-transition-opportunities-and- challenges/power-plant-retirements
4771.03/Vineyard Wind Connector 2-15 Project Description DRI Application Narrative Epsilon Associates, Inc. Vineyard Wind WTGs will take full advantage of a superior wind regime that is found over 14 miles from shore. Accordingly, the Vineyard Wind project is expected to operate at an annual capacity factor in excess of 45%, and the Company’s engineers expect that the Project will be delivering at least some energy from the offshore wind turbine array, located entirely in federal waters, more than 95% of the time. Moreover, summer offshore wind patterns will allow the project to produce substantial power during summer afternoons/early evenings, typical peak power demand periods on the Cape and the Islands.
The Vineyard Wind Connector will also reduce winter electricity price spikes because of its high and stable winter capacity factor. It will enhance energy supply diversity, and as a wind project, will not be affected by possible cold weather gas limitations or supply shortages. As such, it will help to promote price stability and energy security.
2.5.2 Economic Benefits
The Project is expected to generate numerous economic benefits across Massachusetts and the entire New England region. Economic benefits from the Project will be realized throughout the preconstruction, construction, operations and maintenance, and decommissioning phases, and including the following:
♦ The Project will provide significant savings and benefits to electricity customers in Massachusetts, which recent filings at the Department of Public Utilities have calculated at approximately $1.4 billion in total net benefits over the life of the contract.6
♦ In October of 2018, Vineyard Wind finalized a Host Community Agreement (HCA) with the Town of Barnstable, where the upland cable and substation are proposed to be sited. The HCA requires Vineyard Wind to make annual payments to the Town of at least $1.534 million each year in combined property taxes and Host Community Payments. In addition to taxes, the pact guarantees a total Host Community Payment of $16 million, plus an additional $60,000 (adjusted for inflation annually) for each year the Project is in operation beyond 25 years. In January of 2019, the Town of Barnstable dedicated future host community payments from Vineyard wind to a Water Stabilization Fund that will support water resource protection and new water wells within the town. The authorizing legislation stated, “The Host Community Agreement Payments will allow the Town to protect its valuable drinking water resources by making storage, distribution and treatment improvements to the system as well as the development of new wellheads up
6 Petitions for approval of long-term contracts with Vineyard Wind were filed, with supporting documents, at the Department of Public Utilities and docketed as D.P.U. 18-76, D.P.U. 18-77, and D.P.U. 18-78. DOER filed a letter in each docket, which among other things, summarizes benefits to Massachusetts ratepayers. See https://eeaonline.eea.state.ma.us/EEA/FileService/FileService.Api/file/FileRoom/9676907.
4771.03/Vineyard Wind Connector 2-16 Project Description DRI Application Narrative Epsilon Associates, Inc. gradient of the proposed substation. This will also significantly reduce the impact on water rates charged to property owners tied into the town’s water system.”
♦ In 2017, the Project opened and staffed a New Bedford office and occupied additional office space in Boston. The Project has many full-time professionals working on design, permitting, and financing efforts in Massachusetts. In addition, Vineyard Wind’s extensive offshore survey campaigns over the past three years have
drawn on support services from across the southeastern Massachusetts region, including services such as vessel maintenance and repair, fuel and provisioning, protected species observers, inspection and HSE consulting, and pilotage.
♦ The construction and installation process will make use of existing port facilities. On October 22, 2018, Vineyard Wind signed an 18-month lease for use of the New Bedford Marine Commerce Terminal. The lease amount is $6 million a year, for a total of $9 million and includes an option to extend.
♦ The UMass Dartmouth study prepared in support of the Section 83C bid estimated that 1,552 direct full-time equivalent job years7 could be created in Massachusetts during the construction of the Vineyard Wind project. Of this total, the UMass study found that 1,326 job years could be located in southeastern Massachusetts, largely based in New Bedford. These jobs will be in areas such as crane and heavy lift operations, steel fabrication, electrical construction, and civil construction, and will be with firms such as engineering and construction management firms, construction firms utilizing building and maritime trades, and vessel and port operations companies. Additional job years associated with Operations and Maintenance are also anticipated.
♦ Project construction will create opportunities for area maritime industries, including but not limited to tug charters, other vessel charters, dockage, fueling, inspection/repairs, and provisioning. To the extent feasible, construction materials and other supplies, including vessel provisioning and servicing, will be sourced from within the Project area. The Project may also perform fabrication work in Massachusetts.
♦ It is estimated that the Commonwealth and municipalities are anticipated to receive tax payments (including personal income taxes, sales taxes, corporate and payroll taxes, and real and personal property taxes) of between $14.7 and $17 million through the first year of operation alone, and significant tax payments annually thereafter.
7 One full-time-equivalent job year is the equivalent of one person working full-time for one year.
4771.03/Vineyard Wind Connector 2-17 Project Description DRI Application Narrative Epsilon Associates, Inc. ♦ As a result of the October 3, 2018 HCA signed with the Town of Barnstable, Vineyard Wind will pay an additional $16 million to the town above property taxes (themselves estimated at more than $1 million/year), plus an additional $60,000 for each year the Project is in operation beyond 25 years, and will provide other material benefits to the Town. A copy of the HCA is provided as Attachment C. With use of the Covell’s Beach Landfall Site, all onshore Project elements (i.e., Landfall Site, underground duct bank, substation, interconnection to the Barnstable Switching Station) will be located in the Town of Barnstable.
♦ In accordance with the Project’s lease for use of outer continental shelf lands for offshore wind generation, which is with the BOEM, the Project will make substantial annual lease and operating fee payments to the Federal Treasury. Prior to commercial operations, the Project makes annual lease payments of $500,658 to the federal government. Once operations begin, the Project will make annual operating fee payments in accordance with the terms of the lease.
♦ As an element of its Chapter 91 license, the Project will pay a Tidelands Occupation Fee to the Commonwealth. This fee will be calculated based on the area of jurisdictional seafloor occupied by the Project in state waters. It is anticipated that the precise amount of the fee will be determined at the completion of construction based on actual permanent occupation of Commonwealth tidelands, and that the fee will be substantial.
♦ In accordance with a requirement of the Massachusetts OMP review process, the Project will pay an Ocean Development Mitigation Fee. Vineyard Wind proposes that the base fee should be $240,000, adjusted based on post-construction measurements of actual construction and permanent impacts. This fee is intended to compensate the Commonwealth for unavoidable impacts on public interests and rights in the Ocean Management Planning Area and to support planning, management, restoration, or enhancement of marine resources and uses. This fee is in addition to the tidelands occupation fee, and other direct and indirect contributions by the Company.
♦ The Project will make local and regional purchases of goods and services throughout the multi-decade operations and maintenance period.
♦ Additional benefits will include substantial numbers of indirect jobs, persistent Project-related reductions in Locational Marginal Prices for electric power, and other substantial electricity market benefits. The Project’s contractors will utilize local companies for portions of its offshore and onshore work, and will make lease or other payments to local landowners to support onshore construction on Cape Cod.
4771.03/Vineyard Wind Connector 2-18 Project Description DRI Application Narrative Epsilon Associates, Inc. ♦ As part of its winning Section 83C proposal, Vineyard Wind has proposed a $15,000,000 investment in the “Offshore Wind Accelerator Program”. The Program has three major components: (1) a $10 million Offshore Wind Industry Energy Accelerator Fund; (2) a $2 million Windward Workforce Fund; and (3) a $3 million fund for advancing innovations for marine mammal protection. Details of the three elements of the Program are provided in Sections 2.5.2.1 through 2.5.2.3. This program, coupled with Vineyard Wind’s planned start of construction in late 2019, is expected to quickly establish the infrastructure and job-base needed for construction of the Vineyard Wind Project. Development of an offshore wind industry based in Massachusetts and kick-started by the Vineyard Wind project is expected to bring billions of dollars of private investment into the state, helping to diversify and grow the southeastern Massachusetts region’s economy through modernization of local ports, new services such as expanded vessel operations, ongoing research offshore, and skilled workforce training needed to build and operate wind farm facilities. Through strategic investment of Vineyard Wind’s Offshore Wind Accelerator Fund, Massachusetts is poised to maintain its leadership role in reaping the economic benefits of the expanding offshore wind industry.
♦ The Company will continue its efforts to work cooperatively with southeastern Massachusetts educational institutions such as Bristol Community College, Cape Cod Community College, the Massachusetts Maritime Academy, regional Vo-Tech schools, and others to help create opportunities for their students and faculty. Of equal importance, the $2 million “Windward Workforce” initiative described below will be undertaken in partnership with vocational schools, community colleges, and others. Vineyard Wind has already initiated conversations with potential partners including Bristol Community College, Martha’s Vineyard Regional High School, Cape Cod Community College, and Cape and Islands Self Reliance. These partnerships will focus on career development in offshore wind, specialized training and career mentoring, all with a strong emphasis on local hiring.
♦ Vineyard Wind will establish and contribute $1 million annually for 15 years to a Resiliency and Affordability Fund established by the Company, which will support low-income ratepayers, promote clean energy projects in communities on the Cape and Islands, and fund effective use of distributed battery energy storage to enhance the resiliency of local coastal communities in the face of climate change. The Fund will be administered by Citizens Energy and projects implemented by Citizens Energy as well as Vineyard Wind’s community partner, Vineyard Power. The Resiliency and Affordability Fund will support distributed battery energy storage and solar projects in local communities as well as provide credits directly to low-income ratepayers’ electric utility bills. Projects supported by the Fund will be implemented in host communities of the Project such as New Bedford, Martha’s Vineyard, Nantucket, Barnstable, and Somerset. Projects will include solar and energy storage projects and will demonstrate how decentralized battery energy storage will
4771.03/Vineyard Wind Connector 2-19 Project Description DRI Application Narrative Epsilon Associates, Inc. enhance reliability as Massachusetts continues to expand renewable energy resources such as offshore wind.
♦ Considering these various benefits from the Project, the Project will be an important foundational step in creating a thriving, utility scale, domestic offshore wind industry. The Proponent is committed to working with the BOEM, Massachusetts, local and regional officials, local businesses, research and educational institutions, fishermen, environmental advocacy organizations, and other stakeholders to maximize this unique and timely opportunity to establish southern New England as a key center for the offshore wind industry in the United States.
2.5.2.1 Offshore Wind Industry Accelerator Fund ($10 million)
Vineyard Wind is committing to invest $10 million in projects and initiatives to accelerate the development of the offshore wind supply chain, businesses, and infrastructure in Massachusetts. The Fund will attract investments to upgrade or create new facilities or infrastructure needed to develop the offshore wind industry in the Commonwealth. Vineyard Wind is currently working with the Department of Energy Resources, the MassCEC, elected officials, and other stakeholders to determine the best way to make funding decisions.
The Offshore Wind Industry Accelerator Fund aims to support the state’s goals to rebuild and update ports and harbors, encourage and attract additional investments in local infrastructure, and create jobs in critical coastal communities.
Examples of possible investments by the Offshore Wind Industry Accelerator Fund include expansion and improvement of ports available to support offshore wind construction, supporting the establishment of offshore wind manufacturing or fabrication facilities in Massachusetts, and supporting the development of infrastructure or other facilities that will improve the capability to deploy offshore wind on the U.S. East Coast. By establishing such infrastructure and facilities in Massachusetts in the near term, the Commonwealth will benefit from future offshore wind development regardless of where particular projects are located.
Vineyard Wind will work with supply chain companies eager to participate in the U.S.’s first commercial scale offshore wind project and will work to identify opportunities for investment in local infrastructure or facilities. Vineyard Wind’s support of an emerging supply chain will offer Massachusetts an opportunity to leverage both the Industry Accelerator Fund and the purchasing power of the first commercial scale offshore wind project in the U.S. In doing so, Vineyard Wind will serve to attract significant investment in the state's new offshore wind industry such that ratepayers and future projects will benefit from this effort for years to come.
4771.03/Vineyard Wind Connector 2-20 Project Description DRI Application Narrative Epsilon Associates, Inc. 2.5.2.2 Windward Workforce ($2 million)
The Windward Workforce program will recruit, mentor, and train residents of Massachusetts (with a specific focus on southeastern Massachusetts) for careers in the offshore wind industry. These programs will ensure that the Commonwealth is able to provide the workforce needed for the first – as well as future – offshore wind projects in the U.S. The experience gained from working on the first commercial-scale offshore wind project in the U.S., Vineyard Wind, will be invaluable in launching careers in offshore wind for Massachusetts residents. The ultimate objective of the Windward Workforce program is for Massachusetts to have the first available, best trained, and most experienced offshore wind workforce in the U.S.
The Windward Workforce initiative may, for example, fund training courses established for certification in any number of high-skills offshore wind jobs or support services. Vineyard Wind’s proposal to construct an 800MW wind farm approximately 15 miles south of Martha’s Vineyard includes plans for up to 3,600 new jobs, including 1,000 new hires before 2022.
The Windward Workforce program will be undertaken in partnership with vocational schools, community colleges, and others. The Windward Workforce program includes a number of initiatives and policies, including:
♦ Look Local First
Vineyard Wind and all major contractors will actively seek Massachusetts residents as candidates for positions. First-tier supply companies will also actively seek proposals and bids from Massachusetts companies. Through this policy, Vineyard Wind will ensure that Massachusetts businesses and residents have full access to new business opportunities related to the Vineyard Wind project, and that the Company can benefit from the extensive local knowledge of companies that operate in southeastern Massachusetts.
♦ Martha’s Vineyard Wind Working Waterfront
Vineyard Wind has set for itself the goal to have 100% of its operations and maintenance field positions staffed by Martha’s Vineyard residents within five years of the project being operational.
♦ Career Development in Offshore Wind
The program will fund curriculum development and instructor education for courses in “Offshore Wind 101” and other applicable subjects at local vocational schools, high schools, and community colleges within host communities. These courses are designed to create a pipeline to incubate local talent, supporting the industry into the future.
4771.03/Vineyard Wind Connector 2-21 Project Description DRI Application Narrative Epsilon Associates, Inc. ♦ Specialized Training
Through the program, Vineyard Wind will coordinate and fund curriculum development and specific training programs, such as globally recognized certifications for offshore wind technicians, and component manufacturer certifications. These training programs and courses will be done in partnership with community colleges, such as Bristol Community College and Cape Cod Community College, as well as equipment manufacturers and non-profit organizations.
2.5.2.3 Wind and Whales Fund ($3 million)
As part of the Offshore Wind Accelerator commitment, Vineyard Wind has allocated $3 million to helping advance marine mammal protections as the offshore wind industry develops along the East Coast. The Wind and Whales Fund will support development and demonstration of innovative methods and technologies to enhance protections for marine mammals as the Massachusetts and U.S. offshore wind industry continues to grow.
To facilitate sustainable growth of the U.S. offshore wind industry, it will be essential to develop and adapt new technologies and practices to ensure effective protection for marine mammals. The Vineyard Wind project will provide an opportunity to test or demonstrate new tools and methods, so they are more likely to be available for future projects. Such tools and methods could include innovative pile driving technologies, or technologies to better detect and monitor whales to maintain exclusion zones. By supporting innovation in this field, Vineyard Wind will support the state’s planning and management efforts to integrate commercial-scale offshore wind while minimizing impacts to marine mammals. While supporting the coexistence of offshore wind and the marine environment, the fund is also expected to produce benefits that will be applicable to wider-scale marine mammal protections, aiding existing protection efforts while combating climate change, which is a significant threat to the health of marine mammal populations.
The Wind and Whales Fund will be another opportunity for the Massachusetts economy to benefit from offshore wind, given the large existing base of ocean technology companies and ocean-oriented academic institutions within the Commonwealth.
To facilitate a comprehensive discussion of the how the fund can be allocated to best achieve the goal of advancing marine mammal protections quickly, Vineyard Wind will consult with experts in the field, including:
♦ The Offshore Wind industry;
♦ North Atlantic Right Whale experts working with leading research firms;
♦ Academic institutions;
♦ Federal and state government agencies; and
4771.03/Vineyard Wind Connector 2-22 Project Description DRI Application Narrative Epsilon Associates, Inc. ♦ Non-Governmental Organizations (NGOs).
By assembling experts from industry, government, academic, and non-profit sectors, Vineyard Wind aims to ensure that broad ideas, approaches, and proposals are considered. Vineyard Wind is working to develop the mechanisms to implement the $3 million fund. As discussed in the Company’s Section 83C proposal (Section 14, Appendix B) and Section 1.2.2.3 of the SDEIR, Vineyard Wind will convene a panel of experts in the marine mammal field to determine guiding principles to inform allocation of the fund. Initial ideas for the fund that have been discussed are quieter pile-driving technologies, technologies to better detect whales or other mammals in exclusion zones, and supporting efforts to implement fishing practices that provide stronger protections to whales and marine mammals.
Utilizing the nation’s first commercial-scale project to develop best management practices and demonstrate innovative technologies for offshore wind construction and operation in relation to marine mammal protections will also advance the state’s understanding of how to protect and enhance marine habitat with future projects. Information and best practices from this initiative will be shared with regulators and other industry stakeholders.
2.5.3 Environmental Benefits
The Project offers significant environmental benefits. As described in Section 2.5.1, between the decommissioning of nuclear power plants at Pilgrim and Vermont Yankee, and earlier Yankee Rowe (185 MW) and Maine Yankee (900 MW) retirements, New England has lost or is about to lose significant “zero carbon” large-scale generation plants. These market changes increase the complexity and difficulty of achieving the Commonwealth’s aggressive greenhouse gas emissions reduction targets defined in the GWSA: 25% from 1990 levels by 2020 and 80% from 1990 levels by 2050.
The Vineyard Wind Connector would enable 800 MW of zero-carbon electric power to be delivered to the ISO-NE grid. The substantial emissions reductions on the New England power grid due to the Vineyard Wind project will quickly offset construction-phase emissions of regulated pollutants. Table 2-3 quantifies the emissions associated with conventional power generation that would be avoided by using electricity generated from the 800-MW offshore wind project. The displacement analysis uses Northeast Power Coordinating Council (NPCC) New England air emissions data from EPA’s Emissions & Generation Resource Integrated Database (eGRID).8 The analysis conservatively assumes an annual capacity factor of 45% and total Project delivery of 800 MW. Constituents included in the analysis are carbon dioxide (CO2), nitrogen oxides (NOx), and sulfur
8 The displacement analysis uses subregion annual non-baseload output emission rates from eGRID2014(v2) released 2/27/2017 https://www.epa.gov/energy/emissions-generation-resource- integrated-database-egrid
4771.03/Vineyard Wind Connector 2-23 Project Description DRI Application Narrative Epsilon Associates, Inc. dioxide (SO2). The avoided annual emissions of 1,630,000 tons of CO2 is roughly equivalent to taking 325,000 cars off the road.
Table 2-3 Avoided Air Emissions in New England
Pollutant CO2 NOx SO2
Annual Avoided Emissions (tons/year) 1,632,822 1,046 855
As shown in this analysis, the Project would result in substantial emissions reductions in the New England region. The Project will significantly decrease the region’s reliance on fossil fuels and enhance the reliability and diversity of the energy mix on Cape Cod, in the Commonwealth of Massachusetts, and across New England. Thus, the potential Project- related impacts should be considered in conjunction with the Project’s energy reliability, economic, and environmental benefits.
2.6 Project Schedule
The Proponent intends to be ready for commissioning of its turbine array in 2021. To meet this goal, the Company plans to initiate onshore transmission work in late 2019 pending receipt of all necessary permits and approval. The construction of the onshore transmission asset is expected to take a little more than a year including civil work, electrical installation, commissioning, and testing. This will include preparing the Landfall Site for the offshore export cable, installing duct bank, pulling cables on the onshore export cable route, and constructing the onshore substation. As the upland construction has time-of-year limitations due to summer traffic on Cape Cod in addition to anticipated time-of-year restrictions offshore, Project construction will be carefully sequenced.
Onshore, on Cape Cod, there are general summer limitations on construction activities, which the Proponent has reflected in the Project schedule for construction at the Landfall Site and along the onshore transmission route where the route follows public roadway layouts. Activities at the Landfall Site where transmission will transition from offshore to onshore are not expected to be performed during the months of June through September unless authorized by the town. Activities along the onshore transmission route (particularly where the route follows public roadway layouts) will also likely be subject to significant construction limitations from Memorial Day through Labor Day unless authorized by the Town of Barnstable, but could extend through June 15 subject to consent from the local Department of Public Works (DPW). The Proponent will consult with the Town of Barnstable regarding the construction schedule. Typical construction hours will extend from 7:00 AM to 6:00 PM on Monday through Friday. Nighttime work will be performed only on an as-needed basis, such as when crossing a busy road. When needed, nighttime work/extended construction hours, including possible work on weekends, will be coordinated through each Town.
4771.03/Vineyard Wind Connector 2-24 Project Description DRI Application Narrative Epsilon Associates, Inc. Offshore, time-of-year restrictions protective of rare species, wildlife, and marine resources will be in place for construction activities.
Duct banks must be fully prepared prior to cable installation, and cable installation must be complete and tested prior to turbines being energized. Windfarm construction in federal waters is currently scheduled to begin May 2021; however, foundation installation may begin in 2020, only five or six months after upland construction begins. As offshore construction will continue through the summer, onshore construction will be limited to off- road areas and therefore will not progress extensively during that time. The start of commercial operation, with production from a limited number of WTGs, is expected to begin in summer 2021, with the full 800 MW commissioned and operating in mid-2022.
2.7 Permitting and Regulatory Approvals
Table 2-4 below, identifies the anticipated principal environmental reviews, permits, and approvals required for the Project. Required federal permits and permits for work outside of Barnstable County are included for background. By meeting the requirements for each of these review programs, permits, and approvals, the Project will demonstrate compliance with applicable state and local environmental policies.
Table 2-4 Environmental Permits, Reviews, and Approvals for the Preferred Project Route
Agency/Regulatory Permit/Approval Status Authority Federal Bureau of Ocean Energy Site Assessment Plan (SAP) approval SAP approved May 2018 Management (BOEM)9 Construction and Operations Plan (COP) COP filed with BOEM December approval 19, 2017
National Environmental Policy Act Draft Environmental Impact (NEPA) Environmental Review Statement (DEIS) issued November 30, 2018; comment period closes January 21, 2019 Consultation under Section 7 of the Endangered Species Act with National To be initiated by BOEM Marine Fisheries Service and US Fish and Wildlife Service
9 In its review of the COP, BOEM must comply with its obligations under the NEPA, the National Historic Preservation Act (NHPA), the Magnuson-Stevens Fishery Conservation and Management Act (MSFCMA), the Migratory Bird Treaty Act (MBTA), the Clean Air Act (CAA), and the Endangered Species Act (ESA). Thus, BOEM coordinates and consults with numerous other federal agencies including the National Marine Fisheries Service (NMFS), United States Fish and Wildlife Service (USFW), the Environmental Protection Agency (EPA), and the United States Coast Guard (USGC) during the review process. BOEM also coordinates with the state under the Coastal Zone Management Act (CZMA) to ensure that the project is consistent with the state’s coastal zone management program.
4771.03/Vineyard Wind Connector 2-25 Project Description DRI Application Narrative Epsilon Associates, Inc. Table 2-4 Environmental Permits, Reviews, and Approvals for the Preferred Project Route (Continued)
Agency/Regulatory Permit/Approval Status Authority Federal U.S. Environmental National Pollutant Discharge Elimination To be filed (TBF) immediately before Protection Agency (EPA) System (NPDES) General Permit for start of construction Construction Activities
Outer Continental Shelf Air Permit Permit application submitted August 17, 2018. U.S. Army Corps of Individual Clean Water Act Section 404 Filed November 27, 2018 Engineers (USACE) & Rivers and Harbors Act of 1899 Section 10 Permit U.S. National Marine Incidental Harassment Authorization IHA for pile-driving activities Fisheries Service (IHA) submitted September 7, 2018 (NMFS) U.S. Coast Guard Private Aids to Navigation Authorization TBF Federal Aviation No Hazard Determination TBF Administration (FAA) State/Massachusetts (for portions of the project within state jurisdiction) Massachusetts Certificate of Secretary of Energy and ENF filed December 15, 2017; Environmental Policy Environmental Affairs (EEA) on Final Secretary’s Certificate issued Act Office (MEPA) Environmental Impact Report February 9, 2018
DEIR filed April 30, 2018; Secretary’s Certificate issued June 15, 2018
SDEIR filed August 31, 2018; Secretary’s Certificate issued October 12, 2018
FEIR filed December 17, 2018
Certificate issued February 1, 2019 finding that the FEIR adequately and properly complies with MEPA Energy Facilities Siting G.L. c. 164, § 69 Approval Petition filed December 18, 2017; Board (EFSB) evidentiary hearings completed October 26, 2018, briefs filed November 28, 2018 Massachusetts G.L. c. 164, § 72, Approval to Construct Section 72 and Section 40A petitions Department of Public were filed with the DPU on February Utilities (DPU) G.L. c. 40A, § 3 Zoning Exemption (if 15, 2018, together with a request for needed) consolidated review by EFSB, which was granted on April 5, 2018.
4771.03/Vineyard Wind Connector 2-26 Project Description DRI Application Narrative Epsilon Associates, Inc. Table 2-4 Environmental Permits, Reviews, and Approvals for the Preferred Project Route (Continued)
Agency/Regulatory Permit/Approval Status Authority State/Massachusetts (for portions of the project within state jurisdiction) Massachusetts Chapter 91 Waterways License and January 18, 2019 (joint application Department of Dredge Permit & 401 Water Quality Chapter 91 and Water Quality Environmental Certification Certification) Protection (MassDEP)
Massachusetts Non-Vehicular Access Permits TBF Department of Transportation (MassDOT) Massachusetts Board of Special Use Permit Provisional permit issued May 23, Underwater 2017, final permit issued September Archaeological 28, 2017 Resources (MBUAR) Natural Heritage and Conservation and Management Permit (if TBF (if needed) Endangered Species needed) Program (NHESP) Massachusetts Historical Field Investigation Permits (980 C.M.R. § Reconnaissance survey application Commission (MHC) 70.00) filed November 14, 2017 and approved
Permit to Conduct Archaeological Field Investigation issued September 28, 2018; field investigation at substation site completed November 2, 2018; final report will be submitted to MHC in December 2018 or January 2019 (no further investigations recommended) Massachusetts Division Letter of Authorization and/or TBF of Marine Fisheries (MA Scientific Permit (for surveys and pre- DMF) lay grapnel run) Regional (for portions of the project within regional jurisdiction) Cape Cod Commission Development of Regional Impact (DRI) This submission Review Martha’s Vineyard DRI Review January 28, 2019 Commission
4771.03/Vineyard Wind Connector 2-27 Project Description DRI Application Narrative Epsilon Associates, Inc. Table 2-4 Environmental Permits, Reviews, and Approvals for the Preferred Project Route (Continued)
Agency/Regulatory Permit/Approval Status Authority Local (for portions of the project within local jurisdiction)10 Barnstable DPW and/or Street Opening Permits/Grants of TBF; addressed in October 3, 2018 Town Council Location HCA with Barnstable Barnstable Zoning approvals as necessary TBF; exemption from zoning Planning/Zoning requested in EFSB filing; addressed in October 3, 2018 HCA with Barnstable Barnstable Conservation Order of Conditions (Massachusetts To be filed after DRI Review Commission Wetlands Protection Act and municipal wetland non-zoning bylaws) Edgartown Conservation Order of Conditions (Massachusetts Filed December 26, 2019 Commission Wetlands Protection Act and municipal wetland non-zoning bylaws) for offshore route Nantucket Conservation Order of Conditions (Massachusetts Filed January 18, 2019; Hearing Commission Wetlands Protection Act and municipal opened February 6, 2019 wetland non-zoning bylaws) for offshore route
2.8 Outreach and Prior Public and Agency Input
2.8.1 Agency, Municipal and Advocacy Group Outreach
As the Project has progressed, the Company and its representatives have held several meetings with officials on the Cape, including in Barnstable, Yarmouth, Mashpee, and Falmouth, to keep them informed about the Project and to solicit Town input on potential routing and construction sequencing. As design of the two main route alternatives were advanced, Project representatives met with the Barnstable Town Council and with the Yarmouth Board of Selectmen to review Project plans. The Company also met with the full board of the Cape Light Compact, a municipal aggregator that represents 23 towns on Cape Cod and Martha’s Vineyard.
In October 2018, the Company entered into a Host Community Agreement with the town of Barnstable, and received unanimous votes from the Barnstable Town Council supporting Easements associated with the Project. With respect to the Town of Barnstable, as the host community, meetings have been extensive, wide-ranging, and involved, and are naturally
10 Based on additional analysis and refinement of the route within the Offshore Export Cable Corridor, the Company has determined that the preliminary cable alignments will not pass through Mashpee waters (based on the Submerged Lands Act boundary that defines the state/federal boundary); hence, this table has been revised from the SDEIR to exclude the Mashpee Conservation Commission.
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Vineyard Wind and Vineyard Power Cooperative signed a Community Benefit Agreement (CBA), which was recognized by BOEM prior to the Massachusetts offshore wind lease auction in January 2015.
Community outreach and education have been primary objectives for Vineyard Power since its formation in November 2009. Vineyard Power accomplishes these objectives by informing the public about federal and state renewable energy goals and processes, including regulatory frameworks, and ensuring that communities have a voice in reaching desired outcomes. As the Project transitions into permitting and ultimately development and construction, Vineyard Wind and Vineyard Power are committed to continuing the outreach efforts to ensure that local communities welcome, understand, and benefit from the proposed Project. Community outreach, education, and engagement within the communities of Martha’s Vineyard, Nantucket, Cape Cod, and the South Coast will continue along with outreach to state and local agencies and local tribes.
Further information about the partnership between Vineyard Wind and Vineyard Power, as well as Project updates and other information can be found at www.vineyardwind.com.
A summary of meetings held with regulatory agencies, municipal officials and tribal representatives is provided in Attachment L. In addition to the consultations described in Attachment L, extensive and ongoing consultation has been conducted by Vineyard Wind and Vineyard Wind’s community partner, Vineyard Power, with key stakeholders. Vineyard Wind’s fisheries representative has been active in organizing many of the meetings with fisheries stakeholders. The following list includes, but is not limited to, the groups Vineyard Wind has been consulting with and continues to meet with:
♦ Alliance to Protect ♦ Cape Cod Fishermen’s Nantucket Sound; Alliance;
♦ Association to Preserve Cape ♦ Cape Light Compact; Cod; ♦ Climate Action Business ♦ Cape and Islands Self-Reliance; Association;
♦ Cape and Vineyard Electrical ♦ Coalition for Social Justice; Cooperative; ♦ Conservation Law Foundation;
4771.03/Vineyard Wind Connector 2-29 Project Description DRI Application Narrative Epsilon Associates, Inc. ♦ Coonamessett Farm Foundation; ♦ Natural Resources Defense Council; ♦ Eastern Fisheries; ♦ New Bedford Port Authority; ♦ Environment Massachusetts; ♦ New England Aquarium; ♦ Environmental Business Council of New England; ♦ New England Energy and Commerce Association; ♦ Environmental League of Massachusetts; ♦ Northeast Fishery Management Council; ♦ Hercules SLR; ♦ Northeast Fisheries Sciences ♦ Long Island Commercial Fishing Center; Association; ♦ Northeast Fishery Sector ♦ Martha’s Vineyard Fishermen Managers X, XI, XIII, VII, VIII; Preservation Trust; ♦ Port of New Bedford; ♦ Massachusetts Audubon Society; ♦ Recreational Fishing Alliance; ♦ MassCEC; ♦ Rhode Island Fishermen’s ♦ Massachusetts Fisheries Institute; Advisory Board;
♦ Massachusetts Fisheries Working ♦ Rhode Island Habitat Advisory Group; Board;
♦ Massachusetts Fishermen’s ♦ Scallop Industry Advisors Partnership and Support Services; Meeting;
♦ Massachusetts Habitat Working ♦ Seafreeze; Group; ♦ Sierra Club; ♦ Massachusetts Lobstermen’s Association; ♦ Stoveboat - Saving Seafood;
♦ Nantucket Rotary Club; ♦ The Nature Conservancy;
♦ National Academies of Sciences, ♦ Town Dock; Offshore Renewable Energy Development and Fisheries ♦ University of Massachusetts Conference; (various campuses); and
♦ National Wildlife Federation; ♦ Woods Hole Oceanographic Institute.
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Project updates and other information can be found at www.vineyardwind.com. Any interested parties can be added to the Project outreach mailing list by visiting www.vineyardpower.com.
Vineyard Wind plans to maintain an active level of consultation and outreach as the environmental reviews and permitting processes continue, and is available to meet with any interested party.
In addition, Vineyard Wind has conducted extensive fisheries outreach including one-on- one discussions with hundreds of fishermen and over 100 individual meetings. Vineyard Wind has a Fisheries Liaison as well as Fisheries Representatives. The Project has been designed with fishing concerns in mind, and further comments from the fishing community are always being considered. These include:
♦ A grid pattern layout of the WTGs in federal waters to facilitate navigation;
♦ A priority to bury cables over the use of concrete mattresses and/or rocks to protect the cable;
♦ The use of Loran lines in all fishing communication materials;
♦ Outreach via multiple avenues including mailings, emails, texting and phone calls, newspaper notifications, online advertisements, and flyers;
♦ Plans to conduct pre, during, and post construction fisheries studies and to participate in regional fisheries studies; and
♦ A regularly updated Fisheries Communication Plan (see Attachment I).
Vineyard Wind will continue to prioritize this important stakeholder throughout the development, construction, and operational phases of the Project. Fishermen can reach the fishing outreach team anytime at [email protected].
2.8.2 Resident and Abutter Outreach
Regular and ongoing discussions with residents have been an important part of Vineyard Wind’s project development, and have led to important local insights around conditions in the nearshore area, the cable landfall, the onshore transmission route and the substation area. While the permitting process features opportunities for public comment, additional meetings and hearings hosted by the company have allowed the company to engage with the public beyond these prescribed settings in order to allow for a more frequent and broad discussion of project details, concerns and interests.
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The Proponent planned and hosted four community open house events, November 7, 2017 and January 22, 2018 in Barnstable and November 8, 2017 and March 7 2018 in Yarmouth. The open house events allowed interested residents and officials to meet the Project team and ask important questions as well as to view a series of poster boards providing information on the Project. They provided a venue for residents to share ideas, voice concerns, and learn about local and broader project details. The open houses were held in the late afternoon continuing into the evening to accommodate a variety of schedules. Notices advertising the open houses were placed in the Cape Cod Times, Barnstable Patriot, Yarmouth Register and Milestones Newsletter Yarmouth Seniors (online and hard copy); the Proponent also submitted the open house information to the Cape Cod Community Media Center.
A panel discussion intended for Barnstable Project abutters was held at Barnstable High School on March 12, 2018. In advance of the discussion, invitations were mailed to abutters of the export cable routes and/or the proposed substation in the Town of Barnstable, and the meeting was moderated by a Barnstable Town Councilor.
In early April 2018, the Proponent mailed more than 1,900 abutter notices to publicize the EFSB’s Public Statement Hearing held on April 24. The mailing was complemented by newspaper notices published in the Cape Cod Times, Barnstable Patriot, and Yarmouth Register. The April 24 hearing was held at Barnstable High School.
In addition, the Proponent has held regular office hours on Cape Cod, beginning with weekly sessions in March 2018. These events were advertised in the Cape Cod Times, Barnstable Patriot, and Yarmouth Register, along with contact information and a request that residents contact Project representatives to schedule an alternate meeting time if it would be more convenient.
Company representatives have met with neighborhood civic associations, citizens advisory groups, and Cape-based non-profits. Vineyard Wind staff have participated in several climate and environmental forums on the Cape, and served as panelists on discussion sessions and other public events across the Cape.
Though company outreach efforts have focused on the Mid-Cape communities, outreach efforts and presentations have extended as far as the Wellfleet Bay Wildlife Sanctuary, and the Falmouth Board of Selectmen. Supportive comments into our state and federal permitting processes have come from residents of all fifteen Cape towns.
The company plans to continue to actively pursue opportunities to communicate with the public, as community awareness and involvement will remain a high priority after project permitting is complete. We intend to maintain a close relationship with Barnstable officials as well as residents in Barnstable and beyond, through the completion of construction and into project operation.
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2.9 Consideration of Alternatives
For a Project of this complexity, there are interrelated aspects of routing, each of which is important, that must work together to achieve the Project purpose. The offshore route, Landfall Site, onshore route, substation site, and interconnection location are all critical aspects of the overall routing; each element of the Project must be feasible from technical, environmental, and legal/permitting perspectives, and the elements must work together as a coherent solution. Beginning with a broad universe of options, each of these elements was evaluated in a thorough alternatives analysis. (See, for example, the Proponent’s December 18, 2017 EFSB Petition, Section 3.0 of the DEIR and Section 2.0 of the SDEIR).
In particular, the Proponent explored in detail an alternative route with a Landfall Site at New Hampshire Avenue in Yarmouth. This route travelled through roads primarily in the Town of Yarmouth before crossing in the Town of Barnstable to the proposed substation site. This route, shown in Figure 2-11,11 was slightly longer than the Covell’s Beach Route at 6.0 miles. This route was originally proposed at the Proponent’s “Preferred Route” while the Covell’s Beach Route was a “Noticed Alternative”12. However, based on recent positive developments, the Company now proposes the Covell’s Beach Route, rather than the New Hampshire Avenue Route, as its preferred Landfall Site and associated cable route for the Project. The New Hampshire Avenue Route is being maintained as an alternative for purposes of the MEPA and EFSB review but is not included as part of this DRI Application.
The Company’s decision to advance the Covell’s Beach Route as the Preferred Route for the Project was precipitated by several developments:
♦ On October 3, 2018, the Company and the Town of Barnstable signed a Host Community Agreement (HCA) that reflects a shared belief that the Project can benefit the Town of Barnstable and that potential impacts to the Town of Barnstable can and will be minimized and/or appropriately mitigated. The HCA is provided as Attachment C.
♦ Additional mapping and design data were developed for the landfall site at Covell’s Beach, leading to a refined horizontal directional drilling (HDD) approach into Covell’s Beach that will avoid all documented eelgrass and mapped hard bottom, eliminating potential nearshore environmental impacts associated with this route while also reducing costs due to the reduced length of HDD that will be required.
11 Figure 2-11 also shows additional variations on the two main routes that were explored at one time. 12 The Energy Facility Siting Board process requires the identification of both a Preferred Route and a Noticed Alternative.
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♦ The use of the Covell’s Beach as the Project’s Landfall Site will enable the Project to
♦ use the shorter of its offshore route options, thus reducing impacts that are proportional to cable length. The length of the total offshore corridor from the Company’s lease area in federal waters to Covell’s Beach is approximately 4.5 miles (7.2 km) shorter than to New Hampshire Avenue (see Table 1-5 of the SDEIR).
♦ Use of the offshore corridor to Covell’s Beach will eliminate the need to cross the existing Nantucket Cable outside of the Hyannis outer harbor, thereby eliminating any need for cable protection measures at that crossing and avoiding any associated logistical challenges.
♦ At a length of approximately 5.3 miles, the Preferred Route from Covell’s Beach is roughly 0.7 miles shorter than the alternative route from New Hampshire Avenue.
Please refer to the DEIR and SDEIR for additional detailed discussion of the consideration of alternatives for the Project.
2.11 Project Evolution
The Project has evolved since it was first proposed in 2017, as engineering and design have progressed and additional survey data has been collected and assessed and as a result of input in the context of regulatory review and outreach to stakeholders. As design and construction logistics and scheduling advances, the Project will continue to be refined to make sure impacts are minimized and avoided wherever possible. Advancements in Project design since 2017 include the following:
♦ Submarine Cable Concept and Design.
o Construction logistics were simplified by constructing the 800 MW within one phase rather than breaking it up into two 400 MW projects. This simplified schedule allows for reduced impacts, particularly during in-road construction or installation work in communities hosting the on- shore buried cable. This change allowed for the number of export cables proposed to connect the offshore windfarm to the upland transmission system to be reduced from three cables (two 200 MW cables and one 400 MW cable) to two cables (two 400 MW cables), and the size of the upland duct bank required to accommodate the cables was reduced.
o The width of the corridor that is being permitted as an “envelope” within which the cables would be aligned was reduced from up to 2 km to approximately 2,660- to 3,280-foot-wide (810- to 1,000-meter-wide) installation corridor. Moreover based on the ongoing engineering analysis of results from the 2018 marine survey, the location of the
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cables within that corridor has been further refined to avoid and minimize impacts to areas of hard bottom and complex bottom;
o A Landfall site at Great Island in Yarmouth that had a relatively greater impact on eelgrass, rare species habitat and/or coastal wetlands was eliminated;
o Results from marine surveys performed in the spring of 2018, together with ongoing engineering reviews, led Vineyard Wind to select the shorter Western Offshore Export Cable Corridor as the proposed offshore cable route. Accordingly, the previously considered Eastern Offshore Export Cable Corridor was dropped from further consideration by the Proponent. The Eastern Corridor exhibited larger sand waves and was longer, which resulted in a greater areal extent of impacts.
o Refined routing at Covell’s Beach HDD avoids hard/complex bottom and eelgrass, as well as resulting in an overall shorter offshore routing option. With the acquisition of additional information regarding HDD design at Covell’s Beach and the location of nearby resources, Vineyard Wind has refined its routing at that location to avoid and minimize environmental impacts by completely avoiding hard/complex bottom and co-located eelgrass in the vicinity of Covell’s Beach. Specifically, in a refinement of the offshore cable route and Landfall Site, the Proponent is improving the initial HDD layout to allow the Project to avoid an area of Ocean Management Plan (OMP) mapped hard/complex bottom and some recently observed, co-located eelgrass. In consultation with Massachusetts Division of Marine Fisheries (DMF), the Company undertook a supplemental marine survey in late July 2018 to document the location and extent of the eelgrass in this location. .
o The cable protection approach was refined, and the environmental impacts of cable protection were reduced.
♦ Upland Cable Concept and Design.
o Selection of the Covell’s Beach Route as the Preferred Route. Although a primarily Yarmouth-based (so-called “New Hampshire Avenue”) route was originally proposed as the Preferred Route, in 2018 the Company switched to the Covell’s Beach Route. The Company’s decision to advance the Covell’s Beach Route as the Preferred Route for the Project was precipitated by several developments, including the October 2018 HCA between the Town of Barnstable and the Company. The HCA reflects significant community support for the Project, for the cable
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landing at the Covell’s Beach parking lot, and for ongoing cooperation between the Company and the Town of Barnstable.
o With the number of proposed offshore export cables reduced from three to two, the duct bank footprint and associated construction related disturbances have been reduced
o The preferred routing is now entirely within existing roadway layouts, rather than utilizing a utility right of way for a portion of the route. (The utility right of way is being maintained as an alternative but would be constructed only if the all-roadway alternative is subsequently determined to be not feasible.)
o Additional mapping and design data were developed for the landfall site at Covell’s Beach, leading to a refined horizontal directional drilling (HDD) approach into Covell’s Beach that will avoid all documented eelgrass and mapped hard bottom, eliminating potential nearshore environmental impacts associated with this route.
♦ Substation Design Advanced, Including Additional Environmental Safeguards
o The Project engineering team has continued to advance the substation design and has made changes to provide additional environmental safeguards beyond the safeguards included in the original design, including additional containment.
o The Company has enhanced the design of proposed noise barriers at the substation to further reduce potential noise impacts to the nearby Village Green apartment complex. While the exact design of the noise barriers will continue to be refined through modeling as the actual equipment power sound levels become available from manufacturers, the Company has developed an initial approach that includes modifications to the northeast corner barrier walls, geometric revisions to interior barrier walls, and the addition of interior walls. The anticipated noise barriers will also provide complete visual screening of the substation from locations to the east and north.
2.12 Consistency with 2018 Regional Policy Plan
In January of 2019 the 2018 Regional Policy Plan was adopted by the Cape Cod Assembly of Delegates and the CCC. The 2018 Regional Policy Plan is the fifth Regional Policy Plan prepared by the CCC. As described on the CCC’s website, the 2018 Regional Policy Plan is “an evolution of these previous plans, building on the goals and policies set forth and integrating stakeholder input to better define and characterize current challenges and
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solutions”. The Project’s consistency with the 2018 RPP is summarized below, in terms of consistency with its major goals (Section 2.12.1), the identification of “placetypes” (Section 2.12.2) and new application requirements for offshore projects (Section 2.12.3). For reference, this application also provides a discussion of the Project’s consistency with the minimum performance standards of the prior RPP -- see Section 5.
2.12.1 Regional Policy Plan Goals
The 2019 Regional Policy Plan (2019 RPP) adopts 14 goals to promote the values and purposes of the Cape Cod Commission Act and to protect Cape Cod’s assets. These goals and a brief description of the Project’s consistency are identified below.
2.12.1.1 Natural Systems
The goals within the RPP associated with natural systems are identified below, along with a brief description of the Project’s consistency with those goals.
Water Resources
Goal: To maintain a sustainable supply of high quality untreated drinking water and protect, preserve, or restore the ecological integrity of Cape Cod’s fresh and marine surface water resources.
As described in Section 4.2.2, the Company has designed the proposed substation in a manner that will ensure that the presence and use of dielectric fluid at the substation does not present a threat to groundwater. Other than the proposed substation, the Project is predominantly located along roadway layouts and involves standard inert materials such as concrete, PVC conduit, and solid dielectric cable. The proposed cables will not contain any liquids, oils, or other substances that could leak out of the cables.
Onshore duct bank construction will not involve the discharge of wastewater, and it will not create any new sources of stormwater runoff (i.e., no new impervious area will be created along the duct bank route). The proposed substation in Barnstable will not involve discharge of wastewater, and a Stormwater Management Plan has been developed which demonstrates that the substation site will comply with the Massachusetts Stormwater Policy and employ low-impact development (LID) strategies to minimize stormwater runoff and treat any runoff generated from paved areas (i.e., access way and parking) prior to recharge to the ground (see Attachment H).
See also Section 5.3.
Ocean Resources
Goal: To protect, preserve, or restore the quality and natural values and functions of ocean resources.
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As described in Section 4.5, the Offshore Export Cable Corridor has been sited to avoid eelgrass beds and to limit impacts to other sensitive habitats to the greatest extent feasible. For safety purposes, commercial fishing operations may need to avoid the immediate vicinity of construction activities, although no significant effects are anticipated along the Offshore Export Cable Corridor after construction is complete. Some localized changes may occur if cable protection is required in certain areas. The Company’s priority will be to achieve target burial depth of the two offshore export cables and to avoid the need for any cable protection. However, it is possible that achieving sufficient burial depth may be unsuccessful in areas where the seafloor is composed of consolidated materials, making complete avoidance of cable protection measures infeasible. In these cases, cable protection (e.g., a layer of rock or concrete “mattresses”) may be necessary. Rock placed for cable protection can function as good habitat for marine life, since it mimics natural hard/complex bottom. Nonetheless, Vineyard Wind is seeking to minimize the amount of cable protection required not only to avoid and minimize environmental impacts but also to reduce installation time and effort.
Vineyard Wind will not restrict fishing or transit in the Project area, except for required temporary safety zones during construction or maintenance. Commercial fishing impacts will be further mitigated by ongoing communication via the Fisheries Communication Plan and the use of Fisheries Liaisons and Fisheries Representatives; the Fisheries Communications Plan is provided in Attachment I, and was reviewed by federal and state agencies (in Massachusetts and Rhode Island) as well as by stakeholders on Martha’s Vineyard, Cape Cod, and in New Bedford. The Fisheries Communications Plan is an evolving document and will be updated to address feedback received. In addition, Vineyard Wind is developing a framework for a pre- and post-construction fisheries monitoring program to measure the Project’s effect on fisheries resources. Vineyard Wind is working with the Massachusetts School for Marine Science and Technology (SMAST) and local stakeholders to inform that effort and design the study.
No permanent changes in bottom topography, water circulation, or water quality are anticipated as a result of cable installation activities, and short-term impacts from turbidity are expected to be minimal. Existing organisms and habitat along the Offshore Export Cable Corridor are adapted to disturbances associated with active sediment transport and resuspension due to strong tidal currents. Thus, it is anticipated they will quickly adjust to the temporary disturbance from the cable burial. Also, reflecting the dynamic tidal currents in the area, bottom sediments along the proposed route are primarily sand and gravel, and as a result they can be assumed to resettle quickly after disturbance.
See also Section 5.5.
Wetland Resources
Goal: To protect, preserve, or restore the quality and natural values and functions of inland and coastal wetlands and their buffers.
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The proposed onshore duct bank will not impact any wetland resources except for temporary construction-period impacts to Land Subject to Coastal Storm Flowage (LSCSF). Installation of onshore transmission within paved roadways in LSCSF will require only temporary disturbance to the resource.
As a water-dependent project, it is necessary for the offshore export cables to be installed within wetlands. The Vineyard Wind Connector is presumptively water-dependent: the Massachusetts regulations at 310 CMR 9.12(2)(e), provide that “in the case of a facility generating electricity from wind power (wind turbine facility) or any ancillary facility therefore, for which an EIR is submitted, the Department shall presume such facility to be water dependent if the Secretary has determined that such facility requires direct access to or location in tidal waters.” The Secretary’s February 1, 2019 MEPA certificate (page 14) made this determination (see Attachment G).
As a transmission project designed to connect infrastructure in an offshore Wind Development Area located in federal waters to an interconnection point on shore that is part of the regional electric grid, the Vineyard Wind Connector must necessarily cross flowed tidelands and cannot be located away from those tidelands while achieving the expressed Project purpose.
Nonetheless, the Project’s construction-related impacts will be temporary, and no permanent changes in bottom topography, water circulation, or water quality are anticipated as a result of the Project. As discussed in Section 3.1.5, cable protection may be needed in some locations where it is not possible to achieve sufficient burial depth. Vineyard Wind is seeking to minimize the amount of cable protection required not only to avoid and minimize environmental impacts but also to reduce installation time and effort.
See also Section 5.6.
Wildlife and Plant Habitat
Goal: To protect, preserve, or restore wildlife and plant habitat to maintain the region’s natural diversity.
Vegetation clearing proposed for the Project will be limited to the site of the proposed substation, which is located with an Industrial Activity Center Placetype. Of the 6.35-acre leased area, approximately 5.9 acres will be cleared to accommodate the proposed infrastructure. A vegetated buffer at least 50 feet wide will be maintained on the south side of the site; in areas where it will not interfere with the existing utility ROW, a vegetated buffer at least 30 feet wide will also be maintained on the east side of the site. Grading on the substation site will be a cut-and-fill whereby the northern end of the site will be reduced in elevation and the southern portion of the site will be raised, resulting in an even grade.
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The proposed onshore duct bank will follow existing roadway layouts, and the proposed substation will be developed adjacent to other developed parcels; as such, the Project will not contribute to habitat fragmentation. The only fencing proposed for the Project will surround the proposed substation equipment to maintain safety and security, and will not interfere with wildlife migration corridors.
See also Section 5.7.
Open Space
Goal: To conserve, preserve, or enhance a network of open space that contributes to the region’s natural and community resources and systems.
The Project does not involve the creation or preservation of open space. The Project substation is located with an Industrial Activity Center Placetype. Existing land uses will remain unchanged except for the site of the proposed substation, where proposed substation equipment will be contained within a fence line to maintain safety and security. The proposed onshore duct bank is necessarily a linear feature and will predominantly follow existing paved roadways, and the proposed substation will be developed adjacent to other developed parcels; as such, the Project will not contribute to habitat fragmentation.
See also Section 5.8.
2.12.1.2 Built Systems
The goals within the RPP associated with built systems are identified below, along with a brief description of the Project’s consistency with those goals.
Community Design
Goal: To protect and enhance the unique character of the region’s built and natural environment based on the local context.
The Project will not change development patterns or affect land use categories; rather, the Project is intended to deliver up to 800 MW of locally-sourced, renewable energy into New England’s electrical grid. The only above-ground component of the Project on Cape Cod is the proposed substation, which is located immediately south of the existing Barnstable Switching Station on land mapped as an Industrial and Service Trade Area on the CCC Land Use Vision Map, also located within a mapped Industrial Activity Center placetype. The underground duct bank, which is proposed primarily through existing roadways and other existing rights of way (ROWs), will be entirely underground and will not affect the land use or characteristics of adjacent areas.
See also Section 5.13.
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Coastal Resiliency
Goal: To prevent or minimize human suffering and loss of life and property or environmental damage resulting from storms, flooding, erosion, and relative sea level rise.
The Vineyard Wind project will displace more than 1.6 million tons of CO2 annually. See Section 2.5.3. As such, it is a critical element of the Commonwealth’s efforts to reduce greenhouse gas emissions and the associated impacts of climate change and sea level rise. It is a vitally important local effort to resolve a global problem that directly affects Cape Cod.
As a transmission project designed to connect infrastructure in an offshore Wind Development Area located in federal waters to an interconnection point on shore that is part of the regional electric grid, the Vineyard Wind Connector must necessarily cross flowed tidelands and cannot be located away from those tidelands while achieving the expressed Project purpose.
Figure 4-4 in Section 4 illustrates the MassGIS flood zones as defined by the Federal Emergency Management Agency (FEMA) 100-year storm elevations along the Covell’s Beach route. The Covell’s Beach Landfall Site is within Zone VE, which FEMA defines as an area with a 1% annual chance of being flooded with additional hazards due to storm- induced velocity wave action. The proposed work will not permanently alter the existing landscape nor otherwise alter or exacerbate existing coastal storm flooding conditions.
To ensure that the proposed onshore infrastructure will not be vulnerable to shoreline erosion, the Proponent performed a shoreline change analysis. Shoreline change at the Covell’s Beach Landfall Site is shown on Figure 4-7, which illustrates that since 1846 the shoreline has accreted approximately 150 feet. The HDD pit and transition vault would be located well back from the existing high waterline (see Figure 4-8). Based on this analysis, proposed infrastructure associated with the Landfall Site would be sufficiently set back from the shoreline. Furthermore, the Project’s buried ductbank and export cables will comply with performance standards of the Massachusetts Wetlands Protection Act, and construction techniques will ensure the Project will not result in any impacts related to erosion at the Landfall Site. Cable installed via HDD is planned for a depth of roughly 30 feet under the beach at the tideline.
Capital Facilities and Infrastructure
Goal: To guide the development of capital facilities and infrastructure necessary to meet the region’s needs while protecting regional resources.
The underground duct bank and associated onshore export cables will not affect or alter land uses or development patterns. Development of the Project’s substation is proposed to occur within an area mapped as an Industrial and Service Trade Area on the CCC’s Land
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Use Vision Map, and is consistent with that designation. The proposed substation is also proposed on a site located immediately south of the existing Barnstable Switching Station, and hence is consistent with existing land use.
Transportation
Goal: To provide and promote a safe, reliable, and multi-modal transportation system.
The Project, once constructed, will have no permanent effect on traffic; access and egress for the substation site, utilized only for occasional maintenance, will be through the existing access for the site. Temporary construction-related impacts to transportation will be mitigated through Traffic Management Plans, signage, and the use of police details.
Energy
Goal: To provide an adequate, reliable, and diverse supply of energy to serve the communities and economies of Cape Cod.
As described in Section 2.5, the purpose of the Vineyard Wind Project is to provide a commercially sustainable wind energy project within its leased area to meet New England’s need for clean energy. The Vineyard Wind lease area is located in in federal waters off Massachusetts, and is part of the federally-designated Wind Energy Area on the Outer Continental Shelf. The Project will deliver up to 800 MW of power to the New England energy grid, will make a substantial contribution to the region’s electrical reliability, will help meet individual state renewable energy requirements, and will offset over 1.6 million tons of CO2 annually (see Section 2.5). Those requirements include the Commonwealth’s mandate that distribution companies jointly and competitively solicit proposals for offshore wind energy generation for an aggregate nameplate capacity of 1,600 MW. The Project will provide significant savings and benefits to electricity customers in Massachusetts, which recent filings at the MA Department of Energy Resources have calculated at approximately $1.4 billion in total net benefits over the life of the contract
The proposed Vineyard Wind Connector would enhance the reliability and diversity of the energy mix on Cape Cod and in the Commonwealth of Massachusetts. This is particularly important given that several base load/cycling plants have already retired or are slated for retirement (see Section 2.5). Between the decommissioning of nuclear power plants at Pilgrim and Vermont Yankee, and in the 1990s closings of Yankee Rowe (185 MW) and Maine Yankee (900 MW), New England has lost or is about to lose a significant portion of its large “zero carbon” base load plants.
Lastly, Cape Cod is at the outer edge of the regional transmission system. The Cape is essentially supplied by one 345 kV and two 115 kV radial feeds. While recent significant investments in transmission reliability have strengthened the electricity supply to Cape Cod, Vineyard Wind would further improve reliability by feeding power into the center of the
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Cape transmission system. Connecting a substantial electricity supply to Cape Cod will mitigate future costs for ensuring reliable service to Massachusetts customers.
The Vineyard Wind project will be a major source of zero-carbon electric power. The 800- MW project can supply more than the peak load for all of Cape Cod when running at full capacity. As the offshore wind industry has developed, wind turbines have moved further offshore. When coupled with higher hub heights and longer, more efficient blades, the Vineyard Wind WTGs will take full advantage of a superior wind regime that is found over 14 miles from shore. Accordingly, the Vineyard Wind project is expected to operate at an annual capacity factor in excess of 45%, and the Company’s engineers expect that the Project will be delivering at least some energy from the offshore wind turbine array, located entirely in federal waters, more than 95% of the time. Moreover, summer offshore wind patterns will allow the project to produce substantial power during summer afternoons/early evenings, typical peak power demand periods on the Cape and the Islands.
The Vineyard Wind Connector will also reduce winter electricity price spikes because of its high and stable winter capacity factor. It will enhance energy supply diversity, and as a wind project will not be affected by possible cold weather gas limitations or supply shortages. As such, it will help to promote price stability and energy security.
See also Section 5.11.
Waste Management
Goal: To promote a sustainable solid waste management system for the region that protects public health, safety, and the environment and supports the economy.
Since the Project will involve open trenching through existing roadways, there will be asphalt and possibly concrete waste generated during construction. Asphalt and concrete will be handled separately from soil to allow for recycling at an asphalt batching plant and/or recycling facility. Waste materials generated during installation of the Project will be promptly removed for recycling or proper disposal of at a suitable facility.
Packing crates and wood from equipment shipments will be reused or recycled to the extent practicable, or will be disposed of appropriately.
Post-construction, the Project will not generate any significant solid waste.
See also Section 5.10.
2.12.1.3 Community Systems
The goals within the RPP associated with community systems are identified below, along with a brief description of the Project’s consistency with those goals.
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Cultural Heritage
Goal: To protect and preserve the significant cultural, historic, and archaeological values and resources of Cape Cod.
Construction and operation of the Project will not affect any historic buildings or structures. Furthermore, since the export cables will be entirely underground or buried beneath the seafloor, they will have no visual impacts and will not alter existing ground-level conditions or land uses. The site of the proposed substation is already located in an industrial area and is immediately south of an existing substation, and therefore is consistent with existing land uses and will not affect the characteristics of the area.
See also Section 5.13.
Economy
Goal: To promote a sustainable regional economy comprised of a broad range of businesses providing employment opportunities to a diverse workforce.
Given that offshore wind is a new industry to the United States, all direct employment in this industry will be developed as the construction and operations are finalized and benefits will be accessible to all residents of Southeastern Massachusetts.
In cooperation with the MA Clean Energy Center, Vineyard Wind committed prioritizing hiring locally whenever possible. As part of its Windward Workforce initiative, Vineyard Wind is working with the Massachusetts Clean Energy Center to partner with educational and workforce institutions throughout the state to develop and implement training programs that will allow local residents of all backgrounds to enter into the offshore wind workforce. One requirement of workforce training proposals solicited by Mass CEC in November 2018 is the outreach to and inclusion of women and minorities into these training programs. Vineyard Wind expects to use its $2 million Windward Workforce fund to enhance these efforts, working closely with area vocational schools and community colleges.
Additional benefits to Cape residents will be implemented through Vineyard Wind’s $15 million Resilience and Affordability Fund. This fund will assist host communities on the Cape and Islands through low-income rate relief, efficiency projects with a priority on low- income and senior residences, and implementing pilot programs and technologies to boost energy resiliency at places on the grid that are most vulnerable. Recent years have demonstrated that the Cape’s most vulnerable populations (low income and elderly) are most at risk with storms and power outages. This program will help to enhance energy reliability and affordability where it is needed most, providing much needed energy security to the Cape’s most vulnerable residents.
See also Section 5.2.
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Housing
Goal: To promote the production of an adequate supply of ownership and rental housing that is safe, healthy, and attainable for people with different income levels and diverse needs.
The Project does not involve the construction of new housing, and will not have any impacts, positive or negative, on housing on Cape Cod.
2.12.2 Consistency with Cape Cod Placetypes
The 2019 RPP identifies areas with similar natural and built characteristics as distinct "Placetypes," which serve as a conceptual framework for regional planning and regulation. The proposed substation is located within one of eight areas identified as an Industrial Activity Center placetypes on the Cape. As described in the RPP, Industrial Activity Centers are “lands containing industrial uses that are suitable for future industrial activity as well as emerging industries. Industrial Activity Centers are lands without significant resource constraints, are areas with access to major highway corridors, and are of an adequate size to support industrial uses”.
Industrial Activity Centers placetype strategies include the maintain adequate buffers between industrial development and surrounding uses, provide employee services and facilities and access to transit; develop incubator spaces for emerging industry clusters and entrepreneurs, and plan for renewable energy generation facilities.
The Project is consistent with these strategies. The use is appropriate for the site and provides adequate buffers, both in terms of vegetative buffer along independence drive and a sound/screening wall along the property line facing the adjacent apartments. The Project is also consistent with the strategy to encourage renewable energy generation facilities.
2.12.3 Ocean Resources Application Requirements
The new Ocean Resources technical bulletin lists a series of application requirements for projects proposed offshore. The section below lists the requirements along with a short description of compliance or a reference to where in the application the information can be found.
I. List of Required permits and authorizations
“Applicants proposing work in offshore ocean waters should provide a list of all permits and authorizations (not limited to the following) required by local, state, and federal regulatory agencies for the proposed activity…”
See Table 2-4 of Section 2.7 of this application.
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II. Characterization of Existing Environment
An application for DRI review must include a narrative description and map of environmental resources and human use areas potentially affected by the project. Site characterization should encompass sufficient data for establishing natural variability and a baseline from which to assess whether or not a resource is being affected by project activities... Site characterization should:
a. Define the project site. …
See Attachment E of this application and Attachment D of the FEIR.
b. Describe the existing physical environment including:
See Section 1.3 of the SDEIR for geologic information, see Section 2.5 of Attachment L of the DEIR for a description of environmental site conditions.
c. Describe the biological environment within the project site…
See Section 4.5.3.1 of this application; Section 3.1.2 of the FEIR; Section 5.4 of the SDEIR; and Section 4.1.2 of the DEIR for pelagic, demersal and benthic organisms. See Section 4.2 of the FEIR and Section 5.2 of the SDEIR for avifauna. See Section 5.0 of the SDEIR and Section 4.0 of the FEIR for a discussion of endangered species. See Section 4.5.3.1 of this application, Section 3.0 of the FEIR, and Section 5.4 of the SDEIR for fisheries resources.
d. Characterize the socioeconomic marine environment, in both narrative form and on a plan, including:
i. Employment, existing offshore and coastal infrastructure, commercial and recreational fisheries, including typical seasons, location and type
See Section 4.5.3.1 of this application, Section 3.0 of the FEIR, and Section 5.4 of the SDEIR for a description of commercial and recreational fisheries. See Section 1.4 of the ENF for a description of existing infrastructure in the marine environment.
ii. Cultural resources including subsistence resources and harvest practices
See Sections 4.9 and 5.13 of this application and Section 7.0 of the SDEIR
iii. Archaeological resources
See Sections 4.9 and 5.13 of this application, Section 7.0 of the SDEIR, Section 5.0 of the DEIR.
iv. Vessel traffic, including recreational boating and commercial shipping, military activities
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See Section 2.5 of the FEIR, Section 4.1 of the SDEIR, and Section 9.3 of the DEIR.
v. Other space/use conflicts
See Sections 4.6, 4.7, 5.4 and 5.8 of this application, See also Section 4.0 of the SDEIR.
e. Context Map identifying resource areas and important seascape/landscape features within and surrounding the project location(s).
See Attachment D of the FEIR.
III. Analyses of Site Assessment, Construction, and Operational Impacts
DRI applications should provide a narrative analysis of the anticipated impacts from a project during different phases of project implementation. The discussion should reflect completion of analyses designed to assess impacts to different types of resources, as indicated below. Supporting evidence should be provided, as appropriate.
f. Physical resources
i. Anticipated changes in bathymetry, seafloor topography, sediment grain size characteristics, impacts of sediment suspension and turbidity on physical and biological resources through modeling. Evaluate to a distance of at least 200 meters from project boundaries.
For a discussion of impacts from sediment suspension and turbidity, see Section 4.5.3.2 of this application, Section 4.2.2 of the FEIR, Section 1.4.1.4 of the SDEIR, and the Revised Sediment Dispersion Modeling Report provided as Attachment F of the SDEIR.
As described in Section 3.1.2 of this application, prior to cable installation, dredging of the tops of sand waves may occur in discrete locations along the OECC to ensure sufficient burial within the underlying stable seabed. If jetting is used for dredging, the top layer of sediment would be sidecast to either side of the trench. The trailing suction hopper dredge (TSHD) method of dredging uses suction to remove material from the seafloor, depositing it in the “hopper” of the dredging vessel. With this methodology, once the hopper is full, the dredge vessel would navigate approximately 825 feet (250 m) east or west of the dredged area to release the dredged material. This discharge would occur within the surveyed installation corridor where seafloor characteristics are comparable (i.e., within an area characterized by sand waves). Seabed disturbance from any dredging is temporary due to the high mobility rate of the surficial sands, which would immediately work toward attaining the original dynamic equilibrium that existed prior to construction activity.
After any needed dredging is completed, cable installation will occur. Finer granular sediments (silt-sand-gravel) will be displaced during cable installation. As grain size increases, the amount of suspended sediment is reduced with more material redeposited
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closer to the installation tool. Cable installation may result in a slight modification to the seafloor morphology (seabed scar), though impacts will be limited to the immediate and narrow cable installation trench. Overall, the geology resource is not being modified by the construction activity and sediment deposition; rather, the sediments are simply being reworked in place.
Additionally, cable protection may replace existing hard bottom with rock or man-made hard bottom (see Section 3.1.5). In areas of existing coarse material, the cable protection will not modify the coarse deposits underneath (though if concrete mattresses are used, a man-made hard bottom material will be placed over a natural hard bottom layer). Cable protection may increase the seafloor relief slightly in that localized area. Overall, Project impacts to geological resources are largely expected to be short-term and localized.
ii. Analysis of wave and tidal currents patterns and impacts in dredging footprint, affected nearshore/shorelines, etc.
Section 2.5 of Attachment L of the DEIR provides an analysis of wave and tidal current patterns along the OECC. Dredging is discussed in Section 3.1.2 of this application as well as Section 2.2.1 of the FEIR. Impacts to the nearshore environment and shoreline is discussed in Section 4.4 of this application.
iii. For Sand Mining operations, only…:
This does not apply because the Project does not involve sand mining operations.
iv. For Cable or Pipeline installations, only:
1) Site reconnaissance plan of proposed cable/pipeline route extending 100 meters on each side of the installation route to include bathymetry, substrate characteristics (grain size, sediment thickness), fisheries/benthic habitat classification, sensitive marine resources, potential/documented archaeological sites, high resolution scanning of seafloor using sidescan sonar, multi-beam bathymetry to acquire continuous data. Post-installation surveys should also be conducted,
Marine surveys of the OECC in 2017 and 2018 were conducted to inform the technical design of the cable route, characterize benthic habitat, map bathymetry and substrate characteristics, inform assessment of marine archaeological resources, and refine mapping of hard bottom, complex bottom, and eelgrass. The corridor surveyed was a minimum of 810 Meters in width. This survey work is described in Section 2.2.2 of this application and Section 1.3 of the SDEIR. The results of the survey work are illustrated in Attachment D of the FEIR. Post-installation survey work is discussed in Section 3.1.4 of this application.
2) Description of cable/pipeline installation methodology,
See Section 3.0 of this application.
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3) Pre- and Post-construction impacts to benthic wildlife, including habitat structure and function, specific focus on migratory and/or mobile species (e.g. horseshoe crabs) that may be affected by cable/pipeline.
See Sections 4.5.3.2, 5.4.3, and 5.5 of this application.
g. Biological and ecological resources
i. Analysis of impacts to marine organisms, including fish, crustaceans, mollusks and benthic infaunal communities (consult with Division of Marine Fisheries (DMF))
See Sections 4.5.3, 5.4.3, and 5.5 of this application as well as Sections 2.2 and 3.0 of the FEIR. As described in Section 4.5.4, consultations with Division of Marine Fisheries are ongoing.
ii. Analysis of impacts to habitat for marine organisms, including fish, crustaceans, mollusks, etc. (consult with DMF)
See Sections 4.5.3, 5.4.3, and 5.5 of this application as well as Sections 2.1, 2.2, and 3.0 of the FEIR. As described in Section 4.5.4, consultations with Division of Marine Fisheries are ongoing.
iii. Analysis of impacts to other biologically productive habitats (hard bottom, eelgrass, etc.)
See Section 2.2.2, 3.2, 4.5, and 5.4.3 and 5.5 of this application. See also Section 2.1 of the FEIR.
iv. Analysis of impacts to Rare species (listed by the Mass. Div. of Fisheries and Wildlife, as published in the Code of Massachusetts Regulations February 27, 2012) or their habitat,
See Sections 4.3.1, 5.5, and 5.7 of this application and Section 4.0 of the FEIR.
v. Analysis of impacts to marine mammals and sea turtles, ducks, pelagic and sea birds
For an analysis of impacts to marine mammals and sea turtles, see Sections 4.5.2 and 5.5 of this application as well as Section 4.1 of the FEIR. See Section 4.3.1 of this application and Section 4.2 of the FEIR for a discussion of impacts to avian species.
vi. For Wind Turbines, only: Analysis of impacts to both resident and transient/migratory birds and bats and potential impacts to migration corridors.
This does not apply; the Project’s wind turbine generators are located in federal waters outside the jurisdiction of the Cape Cod Commission.
h. Recreational and commercial fisheries, including aquaculture
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i. Analysis of displacement, competition for space and impacts from vessel traffic volume and transit routes
See Sections 4.5.3, 4.7.2, 5.4.3, and 5.5 of this application, Section 3.0 of the FEIR, and Sections 1.0, 3.1, 3.2, and 5.4 of the SDEIR for information on commercial and recreational fisheries in state waters.
ii. Analysis of impacts of activity on inshore and offshore bottom and off-bottom aquaculture operations
See Sections 4.5.3, 4.7.2, 5.4.3, and 5.5 of this application, Section 3.0 of the FEIR, and Sections 1.0, 3.1, 3.2, and 5.4 of the SDEIR for information on commercial and recreational fisheries in state waters.
i. Cultural resources and public viewsheds (historic districts, native American sites, parks, public beaches, coastal vistas)
See Sections 4.9, 5.5, and 5.13 of this application.
j. Identify historic and cultural resources and public viewsheds within the project vicinity and within the project’s viewshed. (contact MHC, Tribal Preservation Officer, and town staff; review town Local Comprehensive and Open Space plans.)
See Sections 4.9, 5.5, and 5.13 of this application.
k. Archeological resources (shipwrecks, other)
See Sections 4.9, 5.5, and 5.13 of this application.
i. Identify onshore and underwater archaeological resources within the vicinity of the project area (contact MHC and MBUAR)
See Sections 4.9, 5.5, and 5.13 of this application.
IV. Resource Protection Plans, required as may be determined necessary
Where the Commission finds that a proposed activity is consistent with the goals and objectives, conditional approval of the project will likely require the approval of resource protection plans. The applicant should prepare narrative and spatial plans to address mitigation and monitoring consistent with the following requirements.
a. Rare Species Protection Plan required where development is allowed in rare species habitat (e.g., terns, colonial water birds) but is demonstrated not to adversely affect such habitat. The applicant should consult with the National Marine Fisheries Service (NMFS), the Natural Heritage and Endangered Species Program (NHESP) and the Division of Marine Fisheries (DMF) in the preparation of this plan. Plans should….
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In consultation with NHESP, a Piping Plover Protection Plan is currently in development.
In addition to state-level reviews, impacts to endangered species and marine mammals are comprehensively reviewed at the federal level under both the Endangered Species Act (ESA) and the Marine Mammal Protection Act (MMPA). The ESA review is conducted by BOEM in consultation with resource agencies (U.S. Fish and Wildlife Service [USFWS] for avian species and National Marine Fisheries Service [NMFS] for marine mammals). These reviews are in addition to the NEPA review, pursuant to which BOEM has produced a DEIS (and will produce an FEIS) that will cover all environmental concerns. The above-described processes will result in the final mitigation measures to be implemented for these important species. The final mitigation measures will be informed by input from Massachusetts State Agencies as well as environmental non-governmental organizations (eNGOs) including, but not limited to, Conservation Law Foundation, National Wildlife Federation, Natural Resources Defense Council, and Massachusetts Audubon Society
b. Marine Mammal and Sea Turtle Protection Plan, required when development is proposed within habitat for whales, sea turtles, and other listed species, or during times of year when these species are present. The applicant should consult with DMF, NMFS and NHESP in the preparation of this plan. Plan should…
As described in Section 4.5.2, NMFS, also known as NOAA Fisheries, has responsibility for implementing the MMPA and is specifically responsible for the protection of whales, dolphins, porpoises, seals, and sea lions. While overseen by a federal agency, the MMPA is not limited to federal waters. Instead, the scope of the MMPA is to provide protection to all marine mammals regardless of location. Vineyard Wind is continuing extensive consultations with BOEM and NMFS to define the most appropriate mitigation measures to protect marine mammals during the different phases of construction. These consultations have addressed activities in federal waters (such as pile driving) but have also included activities in state waters (such as construction vessel transit and cable laying). Working with BOEM and NMFS, Vineyard Wind has identified a suite of mitigation measures that include TOY restrictions for pile driving (an activity only proposed in federal waters) and techniques such as Passive Acoustic Monitoring (PAM) and Protected Species Observers (PSOs), as well as other monitoring options such as aerial- or vessel-based visual observers. Vineyard Wind, BOEM, and NMFS expect ongoing consultations will lead to the final specification of the multiple mitigation measures that are expected to be used to protect marine mammals. Vineyard Wind has applied for an Incidental Harassment Authorization (IHA) with NMFS.
Four species of turtles may occur in the Project area: Loggerhead Sea Turtle (Caretta caretta), Kemp’s Ridley Sea Turtle (Lepidochelys kempii), Green Sea Turtle (Chelonia mydas), and Leatherback Sea Turtle (Dermochelys coriacea). The presence of sea turtles in the Project area is primarily limited to summer and fall months, and no nesting sites are expected near the Landfall Site. The Project is located in an area that lacks critical sea turtle habitat, and the Landfall Site and onshore facilities are not located near known sea turtle nesting beaches. Avoidance, minimization, and mitigation measures employed for marine
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mammals are also applicable to sea turtles. Note that cable laying operations proceed at a very slow speed (less than one knot per hour).
c. Fishery Resource and Habitat Protection Plan, required to determine the presence/absence of resource, and if resource is present, to address potential impacts from the development. The applicant should consult with DMF on the significance of the habitat, development of the plan, and sampling protocols…:
As described in Section 3.1.4, Vineyard Wind has assembled a Benthic Habitat Monitoring Plan (included in Attachment J) that is intended to document habitat and benthic community disturbance and recovery as a result of construction and installation. As described in Section 4.5.3.4, Vineyard Wind is implementing the framework for pre- and post-construction fisheries monitoring programs to measure the Project’s effect on fisheries resources and is working with SMAST and local stakeholders to inform that effort and design the study.
d. Sea Duck Habitat Surveys for projects within 20m water depth or less to determine whether site provides breeding, resting, staging, migration, overwintering habitat for sea ducks…
Some marine birds (e.g., seaducks and loons) may be disturbed by vessels, equipment, and activities, which may lead to temporary displacement from cable installation (MMS, 2007). However, given the limited exposure and short duration of cable installation within Barnstable Country waters, population level impacts to seaducks are expected to be unlikely. Through its siting process for identifying suitable offshore wind lease areas, BOEM removed a significant portion of potential lease area space due to presence of sea ducks.
e. Protection Plan for Eelgrass and other biologically productive benthic habitats. Plan should demonstrate presence/absence and quality of eelgrass, or other productive benthic habitats such as hard/complex bottom. If resources are present, explain how they will be protected during development activities. Plan should include…
As described in Section 5.4.3, the 2018 survey campaign purposely revisited areas that had historically mapped eelgrass beds to further confirm or deny the existence and abundance of the habitat. Investigations in 2018 also infilled areas of the Offshore Export Cable Corridor where data was previously lacking. As described in Section 3.2 and shown on Figure 2-2, the eastward trajectory of the HDD will enable the Project to entirely avoid impacts to an area of hard bottom and co-located eelgrass located offshore from the Covell’s Beach Landfall Site in the vicinity of Spindle Rock.
Vineyard Wind has assembled a Benthic Habitat Monitoring Plan (included in Attachment J) that is intended to document habitat and benthic community disturbance and recovery as a result of construction and installation.
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f. Noise Mitigation and Monitoring Plan for Marine Wildlife. All project proposals should include a noise mitigation plan that includes…:
The principal noise from OECC construction/installation would be from tug and barge vessels used for cable installation. Cable installation is not expected to be a significant source of noise; if a jet plow is used, there will be the sound of water rushing from the nozzles (USDOE MMS, 2009).
Due to regular vessel traffic in and around Nantucket Sound marine mammals and fish in the area are presumably habituated to vessel noise (BOEM, 2014). DP thrusters would likely be used by Project vessels; however, these thrusters are commonly used by the shipping traffic in the area and would be consistent with existing ambient vessel noise. Although received levels of noise may, at times, be above the continuous sound threshold for Level B Harassment (120 dB), NARWs are known to continue to feed in Cape Cod Bay despite disturbance from passing vessels (Brown & Marx, 2000). Fish in the OECC would be able to hear Project vessels, but at sound levels below those that cause injury or stress (USDOE MMS, 2009). Consequently, potential noise risk is predicted to be low, given that noise from vessel traffic associated with installation of the OECC is likely to be similar to background vessel traffic noise.
g. Marine Archaeological Reconnaissance Survey and Protection Plan. All project proposals should include a survey of underwater archeological resources and protection plan, to be developed in consultation with MBUAR.
The Project conducted marine surveys of the OECC in 2017 and 2018 to inform the assessment of marine archaeological resources, which were conducted in consultation with MBUAR. Avoidance, minimization, and mitigation measures for submarine archaeological resources within the Project area will be determined in consultation with MHC and MBUAR through the Section 106 process.
h. For Wind Energy Facilities only: The individual phases of wind energy facility development are characterized by different noise sources during the different phases. The noise mitigation plan for wind energy facilities should address the following development- specific activities:
This does not apply; the Project’s wind turbine generators are located in federal waters outside the jurisdiction of the Cape Cod Commission. i. Avian and Bat Monitoring and Mitigation Plan, for Wind Energy Facilities only, to demonstrate that a WEF can be operated to ensure bird and bat safety during significant migratory events. Plan should include:
This does not apply; the Project’s wind turbine generators are located in federal waters outside the jurisdiction of the Cape Cod Commission.
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j. Habitat Recovery Monitoring Plan, for Sand Mining only:
This does not apply because the Project does not involve sand mining operations.
V. Guidelines for submittal of spatial data associated with assessment and monitoring programs
Data should be provided as latitude and longitude points from GPS; however, geodatabases, shapefiles, and CAD drawings (in that order of preference) may be provided…
The Project will provide data files in the requested format(s).
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Construction Methodology
3.0 CONSTRUCTION METHODOLOGY
Vineyard Wind has selected cable installation techniques to minimize potential impacts while maximizing efficiency. Installation methods are summarized below. The progression of installation will begin with the onshore substation civil works, followed by installation of substation equipment coincident with HDD or open trench work proposed at the Landfall Site as well as installation of the onshore underground cables. Installation of the offshore export cables will follow.
Many of the installation techniques discussed below are routinely used for wind farm cable projects in Europe. On and around Cape Cod, techniques similar to those discussed below were used during installation of transmission cables under Nantucket Sound which service the islands of Martha’s Vineyard and Nantucket, and these techniques are proven effective in dynamic marine environments similar to the proposed Project route.
3.1 Offshore Cable Installation
3.1.1 Installation Technique
Vineyard Wind anticipates that most of the offshore export cable will be installed using simultaneous lay-and-bury via jet-plow. However, other methods may be required in areas of hard bottom or other challenging conditions. The nearshore seafloor in the proposed installation corridor is favorable for jet-plow installation, which is the optimal technique from both an environmental and technical standpoint and is expected to comprise most if not all of the installation in waters under the Commission’s jurisdiction.
Jet-plow and the typical alternative installation techniques are discussed below:
♦ Jet-plow: Jet-plow activities are shown in Figure 3-1. Based around a seabed tractor or a sled deployed from a vessel, the tool typically has one or two arms or booms which extend into the seabed and direct seawater under pressure as the tool moves along the installation route (either simultaneously as the cable is laid on the seafloor or after the cable has been laid), fluidizing the sediment and allowing the cable to sink under its own weight to the appropriate depth or be placed at depth by the tool. Once the arm, or boom, moves on, fluidized sediment will naturally settle out of suspension, backfilling the narrow (approximately one-foot-wide) trench. While jet-plowing will fluidize a narrow swath of sediment, it will not result in sidecast of materials from the trench. Offshore cable installation will result in some temporary elevated turbidity, but this is expected to remain relatively close to the installation activities (see Section 4.5.3.2 for a discussion of sediment dispersion modeling).
4771.03/Vineyard Wind Connector 3-1 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. ♦ Mechanical Plow: A mechanical plow is deployed from a vessel and uses a cutting edge(s) and moldboard to mechanically push through the seabed while feeding the cable into the trench created by the plow. The narrow trench infills itself behind the tool, either by collapse of the trench walls or by natural infill, usually over a relatively short period of time.
♦ Mechanical trenching (e.g., chain-cutter): Typically used only in more resistant sediments, a rotating chain or wheel with cutting teeth or blades cuts a trench into the seabed. The cable is laid simultaneously behind the trencher and the trench collapses naturally or, if required, a blade can be used to push sediment over the cable to backfill the trench.
It is possible, although highly unlikely, that the following more specialized cable installation techniques may be required:
♦ Shallow-water cable installation tractor: This system uses one of the techniques described above, but is deployed from a tractor that operates in shallow water where vessels cannot efficiently operate. The cable is first laid on the seabed, and then a tractor passes over or alongside the cable while operating an appropriate burial tool to complete installation. The tractor is controlled and powered from a self-elevating platform that holds equipment and operators above the waterline.
♦ Pre-trenching: A V-shaped trench is excavated by a plow or similar device, and the sediment is placed next to the trench. The cable is then laid in the trench. Separately or simultaneous to laying the cable, the sediment is returned to the trench to cover the cable. It is highly unlikely that Vineyard Wind will use a pre- trench method, as site conditions are not suitable since sand would simply fall back into the trench before the cable-laying could be completed. Pre-trenching is typically used in areas of very stiff clays, where a displacement plow is used to create a wide trench within the seabed into which the cable is laid. As the cable is laid, the sediment displaced from the trench remains in spoil heaps along the side of the trench. After the cable has been laid into the trench, a backfill plow is towed along the cable route, angled such that it pushes the spoil heaps back into the trench on top of the cable.
♦ Boulder relocation: In areas where large boulders could be encountered, boulder relocation may be employed prior to cable installation. Boulder relocation leaves the route clear of large boulders, facilitating installation and better ensuring proper burial. Boulder relocation is accomplished either by means of a grab that lifts individual boulders clear of the route, or by using a plow-like tool which is moved along the route to push boulders aside.
4771.03/Vineyard Wind Connector 3-2 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. ♦ Precision installation: In situations where a large tool is not able to operate, or in situations where a specialized installation tool cannot complete installation, a diver or ROV may be used to complete installation. The diver or ROV may use small jets and other small tools to complete installation.
♦ Jetting (mass flow excavation): Jetting can be used for cable installation as well as dredging. As described above, jetting uses a pressurized stream of water to push sand to the side. The jetting (mass flow excavation) tool draws in seawater from the sides and then jets this water out from a vertical down pipe at a specified pressure and volume. The down pipe is positioned over the cable alignment, enabling the stream of water to fluidize the sands around the cable, which allows the cable to settle into the trench. This process causes the top layer of sand to be sidecasted to either side of the trench; therefore, jetting would both remove the top of the sand wave and bury the cable. Typically, a number of passes are required to lower the cable to the minimum target burial depth. Jetting is not to be confused with a jet plow used for typical cable installation described above.
The target burial depth will be up to approximately 5 to 8 feet (1.5 to 2.5 meters) below stable seabed. Potential impacts from offshore export cable installation are described and quantified in Section 4.0 (see Table 4-2); sediment dispersion is described in Section 4.5.3.2.
For the offshore export cable installation methodologies described above, the trench would be expected to backfill naturally after passage of the tool since surveys have identified only granular material (not clays) along the Offshore Export Cable Corridor. Where cobbles are present on the seafloor, they are mixed with granular material (e.g., sand), and therefore even though cobbles may be present, the sediment is expected to behave as a frictional material, resulting in natural backfilling of the trench. Given the high-energy marine environment along the Offshore Export Cable Corridor, this trench backfilling is likely to occur in a short period.
In accordance with normal industry practice, a pre-lay “grapnel run” will be made in all instances to locate and clear obstructions such as abandoned fishing gear and other marine debris. Prior to cable-laying operations, an advance vessel or vessels will drag a hook device which will capture marine debris that could otherwise impede or complicate installation. Any recovered debris will be properly disposed of, and any abandoned fishing gear will be turned over to the proper fisheries regulators.
Installation of the offshore export cables will temporarily disrupt a narrow swath of seabed within an approximately 2,660- to 3,280-foot-wide (810- to 1,000-meter-wide) installation corridor. The width of the corridor for potential installation will provide flexibility and maneuverability to avoid impacts and respond to real-time conditions during installation.
4771.03/Vineyard Wind Connector 3-3 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. The proposed offshore cables extending between the Landfall Site and the offshore Wind Development Area (WDA) in federal waters will be deployed from a turntable mechanism aboard a cable ship or cable barge and installed along a surveyed track. The cable burial tools (e.g., jet-plow, plow) can be mounted on a sled pulled by the cable laying vessel, or can also be mounted on a self-propelled underwater tracked vehicle; the tracked vehicle would run along the seafloor using a power feed from the cable-laying vessel. A typical cable-trenching ROV weighs approximately 12 tons in air and gains additional stability on the seafloor when the cutting wheel or chain cutter is inserted into the seabed.
This type of vehicle is routinely used for wind farm cable projects in Europe and was also used during installation of transmission cables under Nantucket Sound which service the islands of Martha’s Vineyard and Nantucket, and has proven effective in dynamic marine environments similar to the proposed Project route.
The Proponent prefers to use vessels equipped with dynamic positioning for the offshore cable installation activities, although these vessels may have limited availability at the time of construction. Dynamic positioning is a computer-controlled system to automatically maintain a vessel’s position by using its own propellers and thrusters. Use of dynamic positioning typically minimizes the need for anchoring associated with offshore cable installation, and thus minimizes potential impacts during installation. Based on feedback from contractors, the Company is evaluating use of installation tools with deeper penetration depths that would be used to achieve sufficient burial depth while reducing or eliminating dredging in areas of sand waves. To enable the option of using these deeper penetration tools, anchoring may be required along the entire Offshore Export Cable Corridor, and particularly in areas of shallow water and/or strong currents. Although this does increase the length of the corridor where anchoring may be necessary, the Company’s engineers have refined the anchoring design to a five-point anchor spread (instead of an eight-point anchor spread) and have modified the marine operations strategy so as to reposition the anchors every 1,312 feet (400 m) (rather than 200 m that had previously been anticipated). Together, these measures will minimize anchoring-related impacts. Anchoring will be contained within the installation corridor. Anchoring is described in further detail below.
The offshore export cables will likely require at least one joint, or “splice”, where two lengths of cable are physically joined together in the field. Upon reaching the joint location, a cable will be retrieved from the seabed and brought inside the cable-laying vessel or other specialized vessel. Inside a controlled environment (a jointing room) aboard the vessel, the two ends of the cable will be spliced together. Once cable splicing is completed, the export cable is lowered to the seafloor. Depending on the design of the cable and joint, the splicing process may take several days. The jointing process must be performed during good weather.
4771.03/Vineyard Wind Connector 3-4 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. Given that this Project consists of two offshore export cables, they will most likely be installed sequentially. Spacing between cables will be up to 100 meters between cables to minimize the risk of damaging the previously-installed offshore cable while also providing sufficient space for future maintenance and repair activities, should they be necessary (see Figure 3-2).
3.1.2 Sand Waves and Potential Dredging
Some areas of Nantucket Sound, including in Barnstable County, have active sand waves. Marine survey work in 2017 and 2018 allowed the Proponent to assess these areas, which may require some pre-cable-laying dredging to ensure that the necessary burial depth can be achieved. Sand waves are dynamic features with changing morphology, and in some locations where sand waves are large, it is necessary to remove the tops of these features to ensure sufficient burial within the underlying stable seabed. Figure 2-3 illustrates where discontinuous dredging of sand waves may be needed within Barnstable County. The Company’s engineers anticipate that the actual length of dredging in Barnstable County waters will be on the order of approximately 650 feet (200 meters) for both cables. No dredging within 2.6 miles of land on Cape Cod is anticipated. It is important to note that dredging will not occur along the entire stretch where sand waves may be present; rather, dredging will only be performed to displace the tops of the sand waves to the extent needed at the time of construction to ensure sufficient burial within the stable seabed. With respect to potential habitat impacts, sand wave areas are intrinsically dynamic and unstable areas, and while dredging will be avoided and minimized wherever possible, those areas which may necessitate dredging are typically sub-optimal areas for benthic organisms. Where dredging is necessary, two main dredging techniques are under consideration: jetting (mass flow excavation) and trailing suction hopper dredge.
Jetting uses a pressurized stream of water to push sand to the side. The jetting (mass flow excavation) tool draws in seawater from the sides and then jets this water out from a vertical down pipe at a specified pressure and volume. The down pipe is positioned over the cable alignment, enabling the stream of water to fluidize the sands around the cable, which allows the cable to settle into the trench. This process causes the top layer of sand to be sidecasted to either side of the trench; therefore, jetting would both remove the top of the sand wave and bury the cable. Typically, a number of passes are required to lower the cable to the minimum target burial depth. Jetting is not to be confused with a jet plow used for typical cable installation. A jet plow uses an array of small high-pressure nozzles that are positioned on a blade or plow operated below the surface of the seabed to fluidize a narrow swath of sediment, allowing the cable to settle in place and be covered all in one motion.
A trailing suction hopper dredge (TSHD) uses suction to remove material from the seafloor, depositing it in the “hopper” of the vessel. With this methodology, once the hopper is full, the dredge would navigate approximately 825 feet (250 m) east or west of the dredged area
4771.03/Vineyard Wind Connector 3-5 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. to release the dredged material; this discharge would occur within the surveyed installation corridor where seafloor characteristics are comparable (i.e., within an area characterized by sand waves).
Jetting is most suitable in smaller sand waves (less than 6.5 feet, or 2 meters), although this is conservative since jetting may be limited to even smaller sand waves (approximately 0.5 meters) to ensure sufficient cable burial is achieved. In contrast, TSHD is not limited to sand waves of a particular size. Accordingly, TSHD is the anticipated methodology for dredging given the heights of sand waves in the Project area, although jetting could be used in smaller sand waves. If jetting is used, it is likely to be used in combination with TSHD. In any event, dredging will be limited to only the extent required to achieve adequate cable burial depth during cable installation.
No dredging is proposed in hard-bottom areas (e.g., boulders, cobble bottom, etc.). The only dredging proposed for the Project is where large sand waves, features that can be considered “complex” due to their bathymetric relief, necessitate pre-cable-laying dredging to ensure that the necessary burial depth can be achieved. As noted previously, sand waves, although they do provide bathymetric variability, are seafloor features that change quickly and hence do not enable the formation of complex benthic communities.
Where required, it is anticipated that an approximately 65-foot-wide (20-meter-wide) corridor will be dredged for each of the two cables. Dredging estimates include estimates for sideslopes; the dredged area will be 65 feet (20 meters) wide at the bottom (to allow for equipment maneuverability) and 1:4 sideslopes are expected. The depth of dredging will vary with the height of sand waves; the dimensions of the sideslopes will likewise vary with the depth of dredging. Dredge volume estimates and direct dredge impact estimates are provided in Table 4-2 in Section 4.5.1. The calculations in Table 4-2 are conservative to reflect the fact that the sand waves will not be uniform over each cable, sand waves are dynamic and constantly-changing features, and site conditions are likely to evolve between the time of permitting and the time of installation.
Dredging will be performed as close in time to cable installation as possible to avoid mobile sand waves recovering the dredged area. The Company plans for dredging to be completed within four weeks of the cable installation activities.
3.1.3 Anchoring
The Company’s technical engineers have been incorporating feedback from potential contractors to determine the zones where anchoring may be required.
Based on feedback from contractors, the Company is evaluating use of installation tools with deeper penetration depths that would be used to achieve sufficient burial depth while reducing or eliminating dredging in areas of sand waves. To enable the option of using these deeper penetration tools, anchoring may be required along the entire Offshore Export
4771.03/Vineyard Wind Connector 3-6 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. Cable Corridor, and particularly in areas of shallow water and/or strong currents. Although this does increase the length of the corridor where anchoring may be necessary, the Company’s engineers have refined the anchoring design to a five-point anchor spread (instead of an eight-point anchor spread) and have modified the marine operations strategy so as to reposition the anchors every 1,312 feet (400 m) (rather than 200 m that had previously been anticipated). As a result, overall potential impacts from anchoring have been reduced. Estimate of impacts from anchoring are provided in Section 4.5.1.
Anchored vessels will avoid sensitive seafloor habitats to the greatest extent practicable. Contractors will be provided with a map of sensitive habitats prior to construction with areas to avoid and shall plan their mooring positions accordingly. Vessel anchors will be required to avoid known eelgrass beds and will avoid other SSU habitats as long as it does not compromise the vessel’s safety or the cable installation. Areas of temporary impacts from anchoring will include portions of the seafloor that could be swept by an anchor cable as the installation equipment moves along the cable. Where it is considered impossible or impracticable to avoid a sensitive seafloor habitat, use of mid-line anchor buoys will be considered, where feasible and considered safe, as a potential measure to reduce and minimize potential impacts from anchor line sweep.
3.1.4 Post-Installation Survey
Vineyard Wind has assembled a Benthic Habitat Monitoring Plan (included in Attachment J) that is intended to document habitat and benthic community disturbance and recovery as a result of construction and installation. Offshore and nearshore geophysical surveys will be conducted post-construction during the operations and maintenance phase of the Project to inspect cable depth of burial and conduct as-built cable surveys. In addition, it is anticipated that short ad-hoc geophysical or geotechnical surveys may be required during construction to verify site conditions. Geotechnical work would only be conducted in areas already cleared for archaeological resources. Any unanticipated discoveries of cultural resources will be reported and avoided during further onsite work, with review and recommendations by the qualified marine archaeologist and as agreed during the Section 106 consultation.
All surveys will use BMPs and industry-standard equipment that has been approved for use previously for offshore renewable energy work. Most of the surveys will entail use of geophysical systems 200 kHz or higher in frequency that do not require any special mitigation (e.g., multi-beam echosounder, side scan sonar, and magnetometer) to avoid impacts to marine mammals. Standard operating conditions (e.g., vessel strike avoidance, separation distances from protected species, necessary notifications, marine trash and debris prevention) for work will be observed.
4771.03/Vineyard Wind Connector 3-7 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. For surveys using sonar equipment less than 200 kHz in frequency (sub-bottom profilers) and any bottom-disturbing investigations that have been previously cleared, in addition to the standard operating procedures identified above, the following mitigation measures will be employed to maintain a level of consistency with offshore project activities:
♦ Notifications when appropriate: national security and military organizations, U.S. Coast Guard (USCG) communication, tribal correspondence.
♦ Vessel strike avoidance measures, including speed restrictions in Dynamic Management Areas and from November 1 through July 31.
♦ Protected Species Observer (PSO) monitoring: PSOs will accompany survey vessels and follow standard monitoring protocols, actively observing an established exclusion zone around each vessel.
♦ Shut down and soft start procedures.
3.1.5 Cable Protection
The Company’s priority will be to achieve sufficient burial depth of the two offshore export cables and to avoid the need for any cable protection. Although cable protection may be necessary in certain areas of where the seafloor is composed of consolidated materials, submerged boulders, or stiff clays that could prevent cable installation from achieving a sufficient burial depth, the multiple and detailed offshore survey campaigns conducted by the Company indicate that in Barnstable County waters, it is unlikely that any significant amount of cable protection will be necessary. The Proponent will seek to avoid and/or minimize the use of such cable protections, and cable protection will only be used where necessary, thus minimizing potential impacts. In areas where seafloor conditions prevent sufficient burial, cable protection is a reliable method for protecting the cable from damage that can occur from anchoring, fishing, or other seafloor activities.
If needed, the methods for cable protection are:
♦ Rock placement, which involves laying rocks on top of the cable to provide physical protection;
♦ Concrete mattresses, which are prefabricated flexible concrete coverings that are laid on top of the cable (alternately, for smaller-scale applications the mattresses may be filled with grout and/or sand, referred to as grout/sand bags);
♦ Half-shell pipes or similar products made from composite materials (e.g., Subsea Uraduct from Trelleborg Offshore) or cast iron with suitable corrosion protection. Half-shell pipes come in two halves and are fixed around the cable to provide mechanical protection. Half-shell pipes or similar solutions are generally used for
4771.03/Vineyard Wind Connector 3-8 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. short spans, at crossings or near offshore structures, where there is a high risk from falling objects. The pipes do not provide protection from damage due to fishing trawls or anchor drags.
Rock placement is likely to be used if relatively larger areas of cable protection are needed, and concrete mattresses are likely to be used only if limited areas of cable protection are needed. Half-shell pipes (e.g. Uraduct) or similar solutions are less likely to be used.
Areas requiring cable protection, if any, will be the only locations where post-installation conditions at the seafloor will permanently differ from existing conditions; however, cable protection is only expected in areas of hard bottom, and the cable protection itself should also function as hard bottom habitat. As shown on Figure 2-1, the preliminary cable alignments will not affect hard bottom within Barnstable County waters, and only a couple small areas of hard bottom are present within the installation corridor; therefore, cable protection within Barnstable County is unlikely.
3.2 Transition from Offshore to Onshore
In the nearshore area off Covell’s Beach, the Company proposes to transition from offshore to onshore using a “trenchless” installation technique called Horizontal Direction Drilling (HDD). HDD is a minimally invasive technique that results in no surface disruption to the beach, nearshore environment, or any coastal wetland resources. As shown on Figure 2-2, the eastward trajectory of the HDD will enable the Project to entirely avoid impacts to an area of hard bottom and co-located eelgrass located offshore from the Covell’s Beach Landfall Site in the vicinity of Spindle Rock.
The HDD technique was used relatively recently for the Comcast/NSTAR Hybrid Cable project, with a landing in Falmouth. In general, there are three principle phases of an HDD. First, a small diameter pilot hole is drilled along a directional path from one surface point to another. Next, the bore created during pilot hole drilling is enlarged (“reamed”) to a diameter that will facilitate installation of a conduit. Lastly, the cable is pulled through the conduit. The section of cable pulled through the HDD conduit are eventually spliced into the landbased cables. In the case of the Project, the cables will be spliced to the onshore export cables within two parallel below-grade transition vaults located in the Covell’s Beach parking lot. For additional detail on the HDD process, please see the DEIR Section 9.1.2.2 and the SDEIR at Section 1.4.2.4.
The HDD is proposed for a total length of 1,000 feet, with installation to a depth of roughly 30 feet at the Covell’s Beach tideline. The Landfall site at Covell’s beach, where the “approach pit” for the drill will be excavated and land-based equipment staged, has sufficient available space. Through agreement with the town, the Company will conduct the HDD in the off-season and will maintain beach access throughout the operation. See Figure 3-3 for a schematic design of the HDD setup. A photograph of the existing Covell’s Beach parking lot can be found in Figure 3-4. Throughout HDD operations, the Proponent
4771.03/Vineyard Wind Connector 3-9 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. will ensure shore-side site security and traffic control, which will be coordinated with Town officials and abutters. Upon completion of construction, the Company has pledged to provide for a full repaving of the Covell’s Beach parking lot, and to support the construction of a new bath house on the site (see Host Community Agreement, Attachment C).
At the HDD exit point, offshore, a shallow 10-foot by 10-foot “pit” would be excavated to expose the conduit end. This temporary receiving pit will be filled back in with the same material once the offshore export cable has been brought to land, thereby restoring the ocean bottom to pre-installation conditions. 3.3 Onshore Duct Bank Construction and Cable Installation
Installation of the onshore export cables will occur in two stages: the first stage will consist of installing duct banks, conduits, and vaults which will house the onshore transmission cables and associated infrastructure; the second stage will consist of pulling/installing the export cables, including splices and terminations. The first stage is expected totake approximately 9 to 12 months to complete, and it is possible that construction will occur simultaneously at multiple locations. The second stage, cable installation, is expected to take approximately five months to complete, although portions of the two stages may overlap. Construction of the onshore cable duct bank system will be performed via open trenching performed with equipment such as excavators and backhoes (see Figure 3-5). All work will be performed in accordance with local, state, and federal safety standards, as well as any Project-specific local requirements.
For the onshore stretch of transmission, each three-core (three-conductor) offshore export cable will transition to three separate single-core 220 kV cables consisting of a copper or aluminum conductor covered by solid cross-linked polyethylene (XLPE) insulation and separate fiber optic cables that will be installed from the Landfall Site to the onshore substation; this transition will occur at the transition vaults proposed at the Landfall Site. Therefore, since the Project will consist of two offshore export cables (each with three cores), it will contain six onshore export cables and a minimum of two fiber optic cables. Like the offshore export cable, the onshore cable will contain no fluids.
Each onshore export cable will have its own conduit within a concrete duct bank that will be installed along the entire length of the onshore cable route. This duct bank, shown in a typical cross-section on Figure 2-4, will be an array of PVC pipes or sleeves encased in concrete. Up to eight approximately 10-inch-diameter conduits spaced approximately 12 inches apart will be installed within the duct bank to accommodate onshore conductors and spare conduits, with additional smaller conduits for fiber optic communications cables; grounding will be accommodated within the duct bank trench.
For the Covell’s Beach route, the majority (roughly 69.1%, or 18,920 feet) of the route will be arrayed two conduits wide by four conduits deep, with the total duct bank measuring 2.5 feet wide and five feet deep. For the remaining approximately 30.9% (8,470 feet) of the
4771.03/Vineyard Wind Connector 3-10 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. route, the array will be four conduits wide by two conduits deep, with the total duct bank measuring 5 feet wide and 2.5 feet deep (see Table 3-1). This “flat” array will be utilized at the start of the route where depth to groundwater is less, and within other areas where utility crossings may benefit from such an array.
Table 3-1 Duct Bank and Trench Dimensions (feet)
Duct Bank Trench Conduit Width at Width at Top Width at Top Width Depth Depth Layout Bottom (0.3 side slope) (0.5 side slope) 4x2 5 2.5 5.5 5.5 8.8 11 (flat) 2x4 2.5 5 8 3 7.8 11 (upright)
The duct bank layout, and hence the excavated trench dimensions, will vary as described in Table 3-1. In general, the width at the top of the trench will vary between approximately 8 and 11 feet, and will be supported by temporary trench boxes or other shoring as appropriate.
The target depth of cover in all cases will be at least three feet, although if required in some instances (e.g., at certain utility crossings), the minimum cover will be 2.5 feet.
In locations where splicing is necessary, the excavated area will be larger, approximately 30 feet wide by 50 feet long, to accommodate a pre-cast concrete two-splice vault which will typically be 9 feet wide by 35 feet long and up to 9 feet deep (outer dimensions). Splice vaults will be installed as two-piece preformed concrete chambers and will be located approximately every 1,500 to 2,500 feet along the duct bank route. Where the onshore route is particularly straight, the distance between splice vaults may be as long as 3,000 feet (the approximate maximum length of export cable that can be effectively transported by truck and pulled through conduit within the manufacturer’s tension specifications). The splice vaults will accommodate cable splicing and cross-bonding of cable metallic sheaths.
Onshore construction is expected to proceed at an average rate of 100 to 200 feet per day.
Proposed trenching will occur primarily within existing roadway layouts except on the variant to the proposed route where the duct bank would follow an existing transmission ROW.
The trench will be backfilled with a combination of Flowable Thermal Backfill (FTB), native material (typically sand and gravel), or road base under roadway areas to original grade. FTB, a thermally-approved concrete mix, will be placed above the thermal concrete- encased duct bank if final cable engineering determines it necessary; FTB is an inert mix of stone, sand, fluidizing agents, and cement that is designed to dissipate heat generated by underground electric transmission cables. Compared with the thermal concrete used to
4771.03/Vineyard Wind Connector 3-11 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. encase the duct bank, FTB is a lower-strength material; as such, FTB is “excavatable,” whereas the thermal concrete around the ducts is more solid. During installation, FTB will flow to fill trench voids and bond with the trench side-walls. Once hardened, FTB will support loads from vehicular traffic above, and eliminate possibility of future settlement. The final backfill in roadway areas will be town-and/or state-required road sub-base graded material upon which base course and finish course pavements are placed. In cross-country areas or landscaped areas, the final backfill above the FTB will typically be a sandy loam, which can be seeded.
During this time traffic will be managed in accordance with TMPs developed in consultation with Town of Barnstable officials (see Section 4.7).
3.3.1 Duct Bank Sequence and Timing
The typical duct bank construction sequence will include the following steps:
1. Pipe will be delivered on flatbed trucks, stockpiled in a local staging area or along the road if space is available; and advanced ahead of the trench.
2. Trench excavation should advance at a rate of 100 to 200 feet per day.
3. Excavated material will be hauled away in trucks daily and recycled or disposed of in accordance with state regulations.
4. At the Landfall Site, fusing or joining of continuous HDPE pipe is planned to be completed in advance of the trench excavation, and will be waiting for assembly into a duct bank array (above ground).
5. Duct pipe is proposed to be assembled into the duct bank array in advance, with required spacers (above ground) then lowered into the trench with slings via heavy equipment.
6. After the duct bank array is secure, concrete trucks will backfill the array in place.
7. Trench areas that are not backfilled by day’s end will be secured with steel plates, set in place to cover and protect the trench overnight. Openings in the shoulder will be protected and barricaded to ensure traffic and pedestrian safety.
8. While new trench excavation advances, backfill will be placed above new concrete- encased sections from the prior day’s work. Backfill will be brought to required grade, and the trench will be secured with steel plates again overnight.
9. Subject to local permit conditions, temporary pavement will be placed at completed trench sections as soon as there is enough work to occupy a paving crew for a full day’s work. Final restoration will be performed in accordance with requirements of
4771.03/Vineyard Wind Connector 3-12 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. the Host Community Agreement (HCA). All work will conform to MassHighway and Town specifications for new road construction. Roadways will be restored to “like new” condition or an alternative mutually agreed upon with the Town and consistent with Town policies and procedures.
This cycle of trench work (steps 2 through 8 above) proceed up to any given vault. A vault crew will attend to vault installation through open trench method, and trench installation will restart on the other site of the vault, allowing the vault crew to work independently. For vault installations, a separate but similar sequence or work will be performed by a separate crew while trench work advances:
1. Vault locations will be excavated to required grade, and a base of leveling stone will be set in place. The current plan is to install a pair of vaults at each location.
2. The vaults (in pre-delivered sections) waiting nearby will be set in place by a crane and fully assembled, including required manway risers.
3. Conduit connections to the vault will then be made from trench ducts in place on each side of the vaults.
4. When all exterior connections are complete, the vault area will be fully backfilled and compacted to grade.
5. Temporary pavement will be placed when vault work is complete, as described in step 10, above.
6. If dewatering is required for vault installation, then procedures as described in Section 4.2.3.1 will be employed.
3.3.2 Environmental Inspector
The Proponent will engage the services of a qualified Environmental Inspector to manage an environmental inspection program and to ensure that construction activities will be in compliance with requirements of applicable federal, state, and local environmental permits and approvals. The Environmental Inspector will be independent of the contractor and will report directly to the Proponent. The Environmental Inspector will have immediate access to the Proponent’s Chief Inspector and will have “stop work” authority relative to environmental non-compliance.
3.3.3 Soil Management
The proposed duct bank trench will be excavated using a “clean trench” technique, where soil will be loaded directly into a dump truck for temporary off-site stockpiling or hauling to an off-site facility for recycling, re-use, or disposal should it not be required for backfilling of
4771.03/Vineyard Wind Connector 3-13 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. trench. The soil will not be stockpiled along the edge of the roadway, thus reducing the size of the required work area and reducing the potential for sedimentation and nuisance dust.
Although not expected, if contaminated soil or other regulated materials encountered along the route, soils will be managed pursuant to the Utility-related Abatement Measure (URAM) provisions of the Massachusetts Contingency Plan (MCP). The Proponent will contract with a Licensed Site Professional (LSP) as necessitated by conditions encountered within the Project area, consistent with the requirements of the MCP at 310 CMR 40.0460 et seq. The Company reviewed the MassDEP Bureau of Waste Site Cleanup’s (BWSC) release sites in the Project area, which revealed the closest regulated hazardous waste site is located 2,400 feet from the proposed onshore route. The Project’s construction-period disturbances will be spatially constrained to the area immediately around the proposed cable route and will not affect any regulated hazardous waste sites.
3.3.4 Air Quality
Although fugitive dust may be generated during construction activities, the relatively short duration of construction at any single location for this Project makes it unlikely that the migration of dust will cause off-site impacts. Furthermore, soil excavation does not typically generate dust due to the natural moisture content of subsurface soils. Nonetheless, the contractor will implement dust control measures as needed during active construction that will primarily consist of street sweeping and using wetting agents to control and suppress dust. Pavement will be cut with a pavement saw, which cuts a trench line in the pavement and across driveways and any intersecting roadways. Pavement will then be removed, trucked away, and disposed of in accordance with applicable regulations. No pavement crushing will occur on-site.
The Proponent will require contractors to use ultra-low sulfur diesel (ULSD) in off-road diesel vehicles, and the Proponent will comply with requirements of the MassDEP Diesel Retrofit Program. The Diesel Retrofit Program, formerly called the Clear Air Construction Initiative of the Clean Construction Equipment Initiative, originated as an air quality mitigation measure for the Central Artery/Tunnel Project. The program encourages users of diesel construction equipment to install exhaust emission controls such as oxidation catalysts or particulate filters on their diesel engines. While MassDEP requires participation in the Diesel Retrofit Program by municipalities applying for funding under the State Revolving Fund for water and wastewater projects, there is no MassDEP requirement for participation by other project proponents. All non-road engines will comply with the non- road diesel fuel sulfur limit of 15 ppm under 40 C.F.R Part 80.
All diesel-powered non-road construction equipment with engine horsepower ratings of 50 and above to be used for 30 or more days over the course of Project construction will either be EPA Tier 4–compliant or will have EPA-verified (or equivalent) emissions control devices
4771.03/Vineyard Wind Connector 3-14 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. such as oxidation catalysts or other comparable technologies (to the extent that they are commercially available) installed on the exhaust system side of the diesel combustion engine.
Vehicle idling will be minimized in accordance with Massachusetts’ anti-idling law, M.G.L. c. 90, § 16A, c. 111, §§ 142A–142M, and 310 CMR 7.11. The Proponent will require the use of ULSD in diesel-powered construction equipment and will limit idling time to five minutes except when engine power is necessary for the delivery of materials or to operate accessories to the vehicle such as power lifts. The Proponent will require its contractors to follow these procedures.
3.3.5 Construction Noise
While intermittent increases in noise levels are expected during construction activities, the Proponent is committed to minimizing these impacts. Construction-related noise levels will comply with applicable sections of the MassDEP Air Quality Regulations at 310 CMR 7.10, particularly subsections (1) and (2), which pertain to the use of sound-emitting equipment in a considerate manner as to reduce unnecessary noise. The Company will make every reasonable effort to minimize noise impacts from construction.
Construction is anticipated to occur during typical work hours (7:00 AM to 6:00 PM) on Monday through Friday, though in specific instances at some locations, or at the request of the DPW of any given municipality, the Company may seek municipal approval to work at night or on weekends. Nighttime work will be minimized and performed only on an as- needed basis, such as when crossing a busy road, and will be coordinated with each Town.
Vineyard Wind will mitigate noise from construction equipment along the selected route near sensitive locations such as residences. The distance between the construction equipment and the sensitive locations will vary along the selected route. Mitigation equipment used may include temporary noise barriers.
Noise mitigation measures expected to be incorporated into the Project include:
♦ Minimizing the amount of work conducted outside of typical construction hours;
♦ Ensuring that appropriate mufflers are installed and maintained on construction equipment;
♦ Ensuring appropriate maintenance and lubrication of construction equipment to provide the quietest performance;
♦ Requiring muffling enclosures on continuously-operating equipment such as air compressors and welding generators;
4771.03/Vineyard Wind Connector 3-15 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. ♦ Turning off construction equipment when not in use and minimizing idling times; and
♦ Mitigating the impact of noisy equipment on sensitive locations by using shielding or buffering distance to the extent practical.
Blasting is not anticipated, nor is construction expected to result in noticeable vibrations.
3.3.6 Solid Waste Management
Since the Project will involve open trenching through existing roadways, there will be asphalt and possibly concrete waste generated during construction. Asphalt and concrete will be handled separately from soil to allow for recycling at an asphalt batching plant and/or recycling facility. Waste materials generated during installation of the Project will be promptly removed for recycling or proper disposal of at a suitable facility.
Packing crates and wood from equipment shipments will be reused or recycled to the extent practicable, or will be disposed of appropriately.
3.3.7 Restoration
Where the trench location requires cutting of pavement, pavement restoration will be carried out in compliance with Section 9.0 of the DPU Street Restoration Standards (from Docket #DTE 98-22) and in conformance with Town of Barnstable requirements. Typically, use of temporary pavement patches is only permitted for work between December 1 and March 31, when bituminous concrete is not available, or if the excavation must be reopened within five working days (e.g., to continue work after a weekend). In general, the length of new excavation completed each day will equal the length of duct bank installed, backfilled, and compacted.
All affected public roads will be restored after construction is complete. Per the requirements of the Host Community Agreement, all work will conform to MassHighway and Town specifications for new road construction. Roadways will be restored to “like new” condition or an alternative mutually agreed upon with the Town and consistent with Town policies and procedures.
In off-road or landscaped areas, the final backfill above the FTB will typically be a sandy loam, which can be seeded. The shoulder will be graded to its pre-existing contours, with slight mounding to allow for settlement. Any disturbed vegetated areas will be loamed and seeded to match pre-existing vegetation. Any lawn-edge that has been affected by duct bank installation, including equipment passage, will be hand-dressed, seeded, and mulched.
4771.03/Vineyard Wind Connector 3-16 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. 3.3.8 Onshore Cable Installation and Testing
Prior to cable installation, each conduit within the installed duct bank will be tested and cleaned by pulling a mandrel (a close-fitting cylinder designed to confirm a conduit’s shape and size) and swab through each of the conduits. When the swab and mandrel have been pulled successfully, the conduit is ready for cable installation.
Six conductors and two fiber optic cables will be installed between two adjacent manholes (vaults). To install each cable section, a cable reel will be set up at the “pull-in” manhole and a cable puller will be set up at the “pull-out” manhole. Following the initial pulling of the mandrel and pulling line through each conduit, a hydraulic cable-pulling winch and tensioner will be used to individually pull cable from the pull-in to the pull-out manhole. This process will be repeated until all cables have been installed.
Once adjacent cable sections are installed, they will be spliced together inside the manholes. Splices will be performed for straight joints with cross-bonding, whereby two cable ends will be joined and then encapsulated with a heat-shrinking material to protect the splice. The splicing operation requires a splicing van and a generator. The splicing van contains all equipment and material needed to make a complete splice. At times, an air conditioning unit may be used to control the moisture content in the manhole. A portable generator may provide the electrical power for the splicing van and air conditioning unit, and the generator would be muffled to minimize noise. Typically, the splicing van will be located at one manhole access cover, the air conditioner will be located near the second manhole access cover, and the generator will be located in a convenient area that does not restrict traffic movement around the work zone.
Once the complete cable system is installed, it will be field-tested from the substation. At the completion of successful testing, the line will be energized.
3.4 Substation Civil Works and Construction
As described in Section 2.4, the Project’s onshore substation is planned for an approximately 6.3-acre leased area directly south of the existing Eversource Barnstable Switching Station in the industrial area known as Independence Park.
The Company has pledged that substation design will include full volume (110%) impervious containment sumps for all equipment containing dielectric fluid, and will provide additional containment capacity of the volume equivalent to a 24-hour, “100”-year” storm event. Containment provisions and safeguards are described further in Section 2.4. This level of containment is above state regulatory standards.
Construction of the substation will include the following steps:
♦ Install perimeter construction fencing and security gate, install initial erosion controls;
4771.03/Vineyard Wind Connector 3-17 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. ♦ Clear and grub the portion of the leased site necessary for construction;
♦ Rough grade the site to provide a level yard area, providing additional erosion controls where needed;
♦ To complete finished site grades, and to balance earth cuts and fills, several retaining walls will be required and excavation for and construction of these walls will be required as part of completing the site grading effort;
♦ Excavate areas required for major component foundations and full volume containment sumps;
♦ Excavate (to rough grades) the drainage swales and basins required for site drainage;
♦ Form and pour major foundations/containment sumps;
♦ Excavate areas required for spread footings, form and pour footings;
♦ Construct base course pavement for the perimeter access road and parking area;
♦ Deliver and place major equipment (e.g., transformers, reactors) using appropriate heavy load vehicles and equipment (transformers are filled with dielectric fluid later in the construction sequence);
♦ Trench areas for underground cabling, prefabricated control/protection cable duct work, install, backfill;
♦ Install ground grid and place crushed stone in yard area;
♦ Deliver and set prefabricated control house;
♦ Deliver and place other equipment (e.g., breakers), and begin to erect buswork;
♦ Complete buswork, begin cabling, including bringing 220 kV transmission lines into site and 115 kV cabling to the adjacent Barnstable Switching Station;
♦ Complete cabling, control wiring, protection systems, etc.;
♦ Install permanent perimeter security fencing and screening;
♦ Test and pre-commission;
♦ Complete finished grading and construction of the drainage swales and basins required for site drainage;
♦ Install finished course paving for the perimeter access road and parking area;
4771.03/Vineyard Wind Connector 3-18 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. ♦ Energize substation;
♦ Final testing and commissioning;
♦ Restore and landscape at periphery of site, especially south and east sides; and
♦ Remove construction stage erosion controls.
Construction and commissioning of the substation is scheduled to occur over a period of approximately 18 months. As described above, much of the substation equipment is prefabricated and work on the site is largely civil construction and assembly/interconnection.
3.5 Laydown and Staging
The Contractor will identify laydown/staging areas necessary to complete construction. It is expected that property adjacent to the substation site (former Cape Cod Times distribution center/parking lot) will be used. The Company has had and continues to conduct consultations with Barnstable officials on appropriate staging areas for construction staging. Other sites within the industrial park may also be used. These specific locations, and any others that have not yet been identified, will not be located within 100 feet of any wetland resource areas, within 100 feet of known private or community potable wells, within 200 feet of perennial waterways, or within the Zone I area of any public water supply wells along the route.
3.6 Construction Equipment and Refueling
Procedures for refueling construction equipment are discussed in Section 4.2.3.2 and will ensure safety and spill prevention. Most of the equipment will be standard on-road construction trucks, which will be refueled at commercial gas stations. The few pieces of heavy, diesel-powered off-road equipment (e.g., hydraulic excavator, front-end loaders) will typically be refueled on site with proper precautions. The proposed duct bank route does not pass through any Zone I wellhead protection areas, and no refueling will occur within Zone I areas or within 100 feet of wetlands or a known private or community potable water well.
3.7 Conclusion
As described above, construction-period impacts from the Project will be spatially constrained and temporary. Appropriate construction management and mitigation measures will avoid and minimize impacts related to air quality, noise, water quality, erosion, and sedimentation.
4771.03/Vineyard Wind Connector 3-19 Construction Methodology DRI Application Narrative Epsilon Associates, Inc. Section 4.0
Resource Area Impacts and Mitigation
4.0 RESOURCE AREA IMPACTS AND MITIGATION
4.1 Introduction
In its letter to MEPA on the SDEIR, the CCC staff noted that the following issue areas should be addressed in this application: water resources, wildlife and plant habitat, wetlands, coastal resources, marine resources, open space, recreation, transportation, economic development, heritage preservation, and community character. The Project has been designed to avoid and minimize the potential for impacts to these resource areas. A discussion of each resource area is provided in the sections that follow. Specific reference to the standards of the Regional Policy Plan (RPP) can be found in Section 5.
4.2 Water Resources
4.2.1 Onshore Cable Route
This section assesses mapped drinking water resource areas along the onshore cable route. Resources identified and evaluated include MassDEP Zone I and II areas, wellhead protection areas determined by hydro-geologic modeling and approved under MassDEP’s Drinking Water Program. Freshwater recharge areas identified by the CCC RPP are also considered, as are the Potential Public Water Supply Areas mapped by the CCC’s Priority Land Acquisition Assessment Project (which focused on the Upper and Mid-Cape Towns with public water supplies, including Barnstable and Yarmouth).
As described in Section 2.3.2, the proposed underground duct bank is predominantly located along roadway layouts and involves standard inert materials such as concrete, PVC conduit, and solid dielectric cable. The proposed export cables will not contain any liquids, oils, or other substances that could leak out of the cables.
Figure 4-1 illustrates water resources along the onshore Covell’s Beach route. The route does not pass through a Zone I area, but 4.18 linear miles of the route pass through Zone II areas. The route is not located near any Interim Wellhead Protection Areas, but much of the route is located within the Barnstable Groundwater Protection Overlay District.
The operational phase of the cable will have no impact on water quality or water supplies. Once the proposed duct bank is installed, backfilled, and repaved, there will be no Project- related sources of erosion or sedimentation, and the export cables will have no capability to generate hazardous waste.
Temporary construction-period considerations related to water quality, drainage, and water supply protection, including refueling procedures, are discussed in Section 4.2.3. Temporary construction-period considerations related to erosion and sediment control are discussed in Section 4.2.3.3.
4771.03/Vineyard Wind Connector 4-1 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. 4.2.2 Proposed Substation
4.2.2.1 Aquifer Protection
The proposed substation site is located within a Zone II Wellhead Protction Area and the Barnstable Groundwater Protection Overlay District (see Figure 4-1). The substation design will include at least full volume (110%) impervious containment sumps for all equipment containing dielectric fluid (i.e., the main transformers, reactors, capacitor banks for the harmonics filter, and any equipment containing oil associated with the synchronous condensers and/or STATCOMs). The Project will also provide full containment under any oil-containing ancillary equipment (e.g., lube oil system) required for the synchronous condensers, which will be installed in an equipment enclosure or building (see Substation Draft Site Plan, Figure 2-7). While sumps for transformers are standard practice, they are not normally used for other lower-volume fluid-filled equipment given the low probability of any leakage. However, the Company has opted to commit to such containment in response to input from local officials and residents. In addition, at the Town of Barnstable’s request, Vineyard Wind has committed to adding additional containment volume in consideration of an extreme rain event. Thus, the Company will adjust the 110% containment volume upwards to account for a simultaneous 100-year, 24-hour rainfall event, which on Cape Cod is conservatively established at 9 inches of rain. Also included in the design as additional mitigation is a common drain system that routes each individual containment area after passing through an oil inhibition device to an oil/water separator before draining to the infiltration basin. These measures are well above industry best practices to ensure protection of the groundwater resource, and are reflective of the Company’s cooperative agreement with the Town of Barnstable and the shared interest in enhanced protection for the water resources of the Cape. In accordance with the Host Community Agreement (HCA), the Company will continue to consult with Town of Barnstable officials regarding the design of the containment system. Finally, the Company is investigating the use of biodegradable dielectric fluid, which is discussed in more detailed in Section 1.4.4.1 of the SDEIR.
During the construction period, the Project will employ proper erosion and sedimentation controls (see Section 4.2.3.3). Refueling procedures are described in Section 4.2.3.2.
4.2.2.2 Stormwater Management
A Stormwater Management Report for the site of the proposed substation is provided in Attachment H. The proposed stormwater management system includes the following low- impact development (LID) strategies, which are designed to capture, treat, and recharge stormwater runoff:
♦ Grass water quality swales;
♦ Sediment forebays;
4771.03/Vineyard Wind Connector 4-2 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. ♦ A deep sump catch basin; and
♦ An infiltration basin.
Post-development stormwater will substantially infiltrate on-site because the substation yard surface will be predominantly permeable (e.g., crushed stone yard). However, during substantial stormwater events, runoff will flow from parking and driveway pavement, roof tops, gravel areas, grassed areas, and woodland areas to the proposed conveyance swales, pretreatment best management practices (BMPs), and infiltration basin.
A LID approach to stormwater management was implemented for this Project by keeping stormwater predominately confined to the substation site by capture and recharge as close to the point of origin as possible. The proposed grass swales, sediment forebays, deep sump catch basins, and infiltration basin provide a treatment train to improve the quality of stormwater runoff, reduce the quantity of stormwater runoff, and provide infiltration and recharge to groundwater. These are considered BMPs by the MassDEP.
The proposed stormwater management design will meet or exceed the Massachusetts Stormwater Policy recommendations for this Project, and the Project will comply with the MassDEP Stormwater Standards. Please see Attachment H for a more detailed description.
4.2.3 Construction-Period Water Resource Management and Mitigation
Construction-period measures to avoid and minimize impacts to water resources are discussed below.
4.2.3.1 Dewatering
Dewatering of the duct bank trench will be necessary during construction in areas where groundwater is encountered, where soils are saturated, or at times when the trench is affected by storm water. Dewatering will likely be necessary in areas where the onshore duct bank route is near wetlands, streams, or other bodies of water. Standard erosion control practices will be employed to minimize erosion during trenching operations and construction activities in general. Areas where groundwater may be encountered will be identified as part of the preconstruction environmental investigation of soils.
4.2.3.2 Refueling
Nearly all vehicle fueling and all major equipment maintenance for construction will be performed off-site at commercial service stations or a contractor’s yard. A few pieces of large, less mobile equipment (e.g., excavators, paving equipment) will be refueled as necessary on-site. Any such field refueling will not be performed within 100 feet of wetlands waterways, or within 100 feet of known private or community potable wells, or within any Town water supply Zone I area. The fuel transfer operation will be conducted by a competent person knowledgeable about the equipment, the location, and with the use of
4771.03/Vineyard Wind Connector 4-3 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. the work zone spill kit. Proper spill containment gear and absorption materials will be maintained for immediate use in the event of any inadvertent spills or leaks. All operators will be trained in the use and deployment of such spill prevention equipment. During construction, equipment will be inspected for incidental leaks (e.g., hydraulic fluid, diesel fuel, gasoline, anti-freeze) prior to site access and on a daily basis at the commencement of each work shift. The Proponent will require its contractor to document the daily inspections as part of the approved means and methods. Small pieces of powered equipment such as generators and pavement saws will be placed in containment bins or on absorbent blankets or pads to contain any accidental fuel spills or leaks. In addition, under no circumstances shall fuel or oils of any kind be stored or brought into any duct bank vault, nor shall there be any re-fueling of equipment either inside a vault or within 100 feet of any vault.
The Contractor will ensure that all refueling is done pursuant to the following conditions, and that impact minimization measures and equipment will be sufficient to prevent discharged fluids from leaving the construction zone or reaching wetlands or waterbodies, and be readily available for use. These will include some combination of the following:
(a) dikes, berms or retaining walls sufficiently impervious to contain spilled oil;
(b) sorbent and barrier materials in quantities determined by the Contractor to be sufficient to capture the largest reasonably foreseeable spill;
(c) drums or containers suitable for holding and transporting contaminated materials;
(d) curbing;
(e) culverts, gutters, or other drainage systems;
(f) weirs, booms, or other barriers;
(g) spill diversion or retention ponds;
(h) sumps and collection systems;
(i) secondary containment of non-mobile pumps;
(j) The Contractor will prepare a list of the type, quantity, and storage location of containment and clean up equipment to be used during construction, and Vineyard Wind will review this list prior to construction;
(k) All spills will be cleaned up immediately. Containment equipment will not be used for storing contaminated material; and
(l) Date and location of refueling activities will be documented and maintained by the contractor and made available to Vineyard Wind for review.
4771.03/Vineyard Wind Connector 4-4 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Neither the onshore cable route nor the substation is in a Zone I area. Moreover, Vineyard Wind will prohibit the refueling of machinery in Zone I areas. Spill containment equipment will be immediately available throughout construction in the unlikely event of a leak. In addition, under no circumstances shall fuel or oils of any kind be stored or brought into any duct bank vault, nor shall there be any re-fueling of equipment either inside a vault or within 100 feet of any vault.
4.2.3.3 Erosion and Sediment Control
The Proponent’s objective is to minimize the potential for erosion and sedimentation impact during Project construction, and to effectively restore any disturbed areas. The Proponent will meet these objectives by implementing the erosion and sediment control measures described in this section. In general, the measures are designed to minimize erosion and sedimentation by:
♦ Minimizing the quantity and duration of soil exposure;
♦ Protecting areas of critical concern during construction by redirecting and reducing the velocity of runoff;
♦ Installing and maintaining erosion and sediment control measures during construction;
♦ Establishing vegetation where required as soon as possible following final grading; and
♦ Inspecting the construction route and maintaining erosion and sediment controls as necessary until final stabilization is achieved and final inspections completed.
The Company will ensure that its contractor implements and maintains erosion and sediment control measures during construction. The environmental inspector or designee (such as a construction supervisor) will provide oversight of the contractor’s activities. The sections below include erosion and sediment control techniques that apply to all areas of construction.
Temporary Erosion Control Barriers
Hay/straw bales and silt fences are interchangeable, except where noted below. Temporary erosion control barriers will be installed prior to initial disturbance of soil and maintained as described below:
♦ At the outlet of a slope break when existing vegetation is not adequate to control erosion;
4771.03/Vineyard Wind Connector 4-5 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. ♦ Down slope of any stockpiled soil in the vicinity of waterbodies and vegetated wetlands;
♦ At sideslope and downslope boundaries of the construction area where run-off is not otherwise directed by a slope break;
♦ Maintained throughout construction and remain in place until permanent revegetation has been judged successful, upon which they will be removed;
♦ At boundaries between wetlands and adjacent disturbed onshore areas;
♦ As necessary to prevent siltation of ponds, wetlands, or other waterbodies adjacent to/downslope of the Project;
♦ At the edge of the construction area as needed to contain soil and sediment; and
♦ Catch basins along the work area will be protected using “silt socks” and perimeter hay bales. The silt socks and hay bales will be installed before pavement removal and trench excavation begins and will remain in place until the area is repaired and the shoulder repaved and revegetated. Silt socks will be emptied after each rain event, and catch basins and manholes will be cleaned once sediment occupies half the sump available. Structures will be inspected on a weekly basis.
Temporary erosion control barriers will be inspected daily in areas of active construction or equipment operation, weekly in areas with no construction or equipment operation, and within 24 hours of a rain storm event that is 0.5 inches or greater.
Silt Fence Installation and Maintenance
Any silt fence used as a construction-period control will be installed as directed by the manufacturer and applicable permit conditions. Accumulated sediment will be removed and the fence inspected to ensure it remains embedded in the soil as directed. Sufficient silt fence will be stockpiled onsite for emergency use and maintenance.
Hay/Straw Bale Installation and Maintenance
Hay/straw bale installation and maintenance will be performed as follows:
♦ Hay/straw bales will be anchored in place with at least two properly sized wooden stakes;
♦ Bindings on bales will be horizontal;
♦ Bales shall be replaced if damaged or allowing water to flow underneath;
4771.03/Vineyard Wind Connector 4-6 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. ♦ Damaged bales will be replaced with new bales as deemed necessary by the Environmental Inspector;
♦ A sufficient supply of bales will be maintained on site for emergency use;
♦ Bales bound with wire or plastic will not be used; and
♦ Properly placed and staked straw wattles or fiber rolls may be used in lieu of hay bales in certain circumstances. Such substitutions will be approved by the Environmental Inspector in advance.
4.3 Wildlife and Plant Habitat
4.3.1 Rare Species
The Project’s offshore transmission within Barnstable County waters is located entirely within Priority Habitat, including areas that are considered foraging habitat associated with Roseate Tern, Piping Plover, and Least Tern. For added context, a comprehensive discussion of potential impacts to coastal and marine birds from the Vineyard Wind Connector and elements of the broader energy project in federal waters, along with avoidance, minimization, and mitigation measures, is provided in Section 6.2 of the Company’s Construction and Operations Plan (COP), which is accessible from the BOEM website at https://www.boem.gov/Vineyard-Wind/. The COP includes discussion of many specific species, including Massachusetts-listed species. Rare species impacts and mitigation are also discussed in detail in Section 4.0 of the FEIR, 5.0 of the SDEIR, and 8.0 of the DEIR, all of which are incorporated by reference.
In addition, most shoreline between Hyannisport and Osterville in Barnstable is also mapped as Priority Habitat for migratory shorebirds, including the portion of the Landfall Site that is seaward of the parking lot at Covell’s Beach. Neither the parking lot nor the undeveloped portion of the site north of the parking lot are mapped as Priority Habitat (see Figure 4-2 in Attachment A).
Vineyard Wind has been in close communication with NHESP regarding proposed Project activities and potential impacts to rare and endangered species. Through these consultations, NHESP has communicated its interest in addressing potential impacts to offshore foraging and onshore nesting habitats of rare and endangered shorebirds including the Roseate Tern (Sterna dougallii), Least Tern (Sternula Antillarum), and Piping Plover (Charadrius melodus). NHESP has also expressed concerns about potential impacts to Sand Lance (Ammoytes sp.), a small burrowing fish that is an important prey species of the Roseate Tern.
In response to these concerns, the Project has incorporated specific measures into the Project intended to avoid or minimize potential impacts to Roseate Tern and other avian resources as summarized in the following sections.
4771.03/Vineyard Wind Connector 4-7 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. The Massachusetts Endangered Species Act (MESA) checklist was filed with NHESP on December 17, 2018.
4.3.1.1 Offshore Impacts and Mitigation
Offshore, the NHESP has mapped all state waters within Nantucket Sound and Muskeget Channel as Priority Habitat of state-listed rare species (Massachusetts Natural Heritage Atlas, 14th Edition, 2017). As a result, the Offshore Export Cable Corridor will necessarily cross priority habitat within state waters. NHESP has determined that the Project’s offshore transmission is within the habitat of state-listed migratory birds including Least Tern (Sternula antillarum), Common Tern (Sterna hirundo), Piping Plover (Charadrius melodus), and Roseate Tern (Sterna dougallii), which is also a federal-listed species.
As is the case with all vessel traffic, including existing vessel traffic, some marine birds may be disturbed by vessels engaged in construction activities, which may lead to temporary displacement during cable installation or in a very rare instance a bird may collide with lighted vessels during low-light conditions. There is very low probability of any impact due to the temporary nature of cable-laying activities; at the very most vessels will be active for several weeks.
Sand wave dredging and cable installation may result in temporary increases in suspended sediment; however, such impacts will occur over a limited time period (see Section 4.5.3.2). In addition, the suspended sediment thresholds are not expected to have any long-term effect on mobile fish species, including sand lance. At NHESP’s suggestion, pre- and post- construction monitoring of sand lance is included as part of the Benthic Habitat Monitoring Plan (included as Attachment J). In addition, the area of disruption will be along a narrow corridor with vast, unaffected adjacent areas which also provide suitable foraging opportunities to any affected species. Due to these factors, cable installation activities are not expected to have any significant effect on feeding activities of diving and plunging birds.
4.3.1.2 Onshore Impacts and Mitigation
In early consultations with NHESP, agency representatives advised that Piping Plovers are typically in residence in southeastern Massachusetts between April 1 and August 31, and that time-of-year (TOY) restrictions may be required if the Company anticipates disturbance to areas of mapped Piping Plover habitat at Covell’s Beach. Project construction at the Covell’s Beach Landfall Site will be entirely contained within paved surfaces and is not within mapped habitat. Furthermore, since the proposed cable installation method at Covell’s Beach is by HDD and would extend underneath the beach, there will be no disturbance to any areas of mapped Piping Plover habitat. The temporary HDD setup in the parking lot would be in the tourist offseason.
4771.03/Vineyard Wind Connector 4-8 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. In discussions with NHESP, potential noise disruption to existing nests was raised as a concern, and a mitigation option was discussed at a consultation meeting on August 21, 2017. NHESP suggested that if the HDD could begin after August 31 or before April 1, then a pair of birds would be aware of the noise prior to selecting a nesting location. The Company will comply with this requirement.
4.3.2 Wildlife and Plant Habitat
A Natural Resources Inventory (NRI) was conducted at the proposed substation site, which is located on the eastern portion of a previously-developed commercial property at the corner of Independence Drive and Communication Way in Barnstable (see Attachment K). More specifically, the substation site consists of approximately 6.35 acres of land that is mostly wooded but also includes some existing parking areas and a small building associated with the previously developed commercial property. Approximately 5.9 acres will be cleared for construction of the substation.
Two separate site visits were conducted for the wildlife habitat assessment within one hour of sunrise or sunset and in good weather as specified in Technical Bulletin 92-002. These visits were completed in October 2018. Field observations were performed by a qualified ecologist with prior experience conducting natural resource inventories on Cape Cod.
During these site visits, plant species, their relative abundance for the various strata (tree, shrub/sapling), and groundcover were observed and recorded. Soils were probed to a depth of twenty inches, and soil horizons and depth of leaf litter was recorded. Site evaluations included wildlife species observations as well as documentation of important habitat features for avifauna, mammals, herpetiles, and rare species.
The field effort revealed a vegetation that is consistent with that of a Pitch Pine-Oak forest, which is the most common forest type on Cape Cod and southeastern Massachusetts. The site is isolated by surrounding commercial, industrial, and residential developments: the western part of the property is an active trucking/storage operation (formerly Cape Cod Times Production center); the existing Eversource Barnstable Switching Station is located to the north; an existing overhead utility ROW and the Village Green apartments access drive is east of the site; and the multi-lane Independence Drive is present to the south.
The substation site provides some features that are conducive to wildlife habitat. Standing snags (dead pitch pines) and downed tree limbs, were noted, and several small game trails were observed. However, because the site lacks any available or nearby water source, it does not provide suitable habitat for amphibians or other non-avian animal species with limited home range. In addition, the wildlife habitat of the subject property has been degraded by surrounding developments, which have essentially isolated this relatively small forested area from the much larger areas of similar forested habitat located in the vicinity. Lastly, the nearly constant noise from the nearby airport, as well as highways and commercial operations further degrades the wildlife habitat of this site.
4771.03/Vineyard Wind Connector 4-9 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. 4.4 Onshore Wetlands and Coastal Resources
4.4.1 Wetlands
The Project will temporarily alter a small area of Coastal Dune and Land Subject to Coastal Storm Flowage (LSCSF)at the Covell’s Beach Cable Landfall Site itself. The Covell’s Beach onshore route does not pass within the 100-foot buffer zone of any other inland wetland resource, and will have no impacts to Coastal Beach (due to the use of HDD). Summary descriptions of the wetland resource areas and buffer zones crossed by the Covell’s Beach onshore route are presented in Table 4-1 below, and the wetland resource areas are shown on Figure 4-3.
Table 4-1 Temporary Wetland Impacts along the Covell’s Beach Route.
Wetland Resource Area Temporary Impact Coastal Dune Up to approximately 800 sf1 Coastal Beach 0 Land Subject to Coastal Storm Flowage 600 linear feet (within roadway) 1There is a small area of dune that will be crossed between the Covell’s Beach parking lot and Craigville Beach Road.
These areas temporarily disturbed by construction will be restored to their existing condition, which will primarily involve repaving existing roadways (see Section 3.3.7).
Installation and maintenance of appropriate erosion and sedimentation controls will be implemented during construction, as discussed in Section 4.2.3.3. These controls will be monitored and maintained until the affected area is determined to be suitably stabilized and restored in compliance with applicable permit conditions. The Project will comply with the NPDES General Permit for Stormwater and with Stormwater Pollution Prevention Plan (SWPPP) requirements, as well as with other restrictions as may be applied by the Barnstable Conservation Commission in accordance with local wetlands-related bylaws, regulations, and codes. Appropriate erosion control and spill prevention technology will be provided where needed, and these controls will be closely monitored and managed.
4.4.2 Floodplain
Figure 4-4 demonstrates that only the Landfall Site and immediately proximate stretch of onshore routing are within existing Federal Emergency Management Agency (FEMA) flood zones. The site of the proposed substation is not within the flood zone. The Project will have no permanent impacts to flood zone, and will not alter any elevations within the flood zone. The Proponent has evaluated the Project’s vulnerability to sea level rise and shoreline change, as discussed below.
4771.03/Vineyard Wind Connector 4-10 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. 4.4.3 Sea Level Rise
The Company has evaluated the Project’s vulnerability to sea level rise by using data from the CCC’s Sea Level Rise Viewer, which covers all of Barnstable County on Cape Cod. This tool depicts sea level rise at one-foot increments between 1 and 6 feet, and demonstrates the effects of this bathtub scenario of sea level rise on Cape Cod. The model incorporates overlays from the FEMA Flood Insurance Rate Maps (FIRMs) and the National Weather Service’s SLOSH (Sea, Lake, and Overland Surges from Hurricanes) model.
The bathtub model accounts for rising water levels but does not take into account natural events like storm surge and does not model the rate of sea level rise. Rather, it evaluates effects from a consistent rise of water (like filling a bathtub). The tool uses mean higher high water (MHHW) as the base sea level elevation; MHHW is the average of the higher high water height of each tidal day observed over the National Tidal Datum Epoch. Sea level is then raised in one-foot increments to illustrate inundation under various sea level rise scenarios. The analysis for this Project, which has a projected life of up to 30 years, used sea level rise scenarios of 1 foot and 3 feet; a scenario involving 6 feet of sea level rise would be more appropriate for a period spanning 100 years. Modeled scenarios such as these are meant to represent potential flooding to inform planning decisions, but are not suitable for use as actual calculations.
As shown on Figure 4-5, neither a one-foot nor a 3-foot rise in sea level would result in any inundation of the Project’s onshore export cable route or substation site.
The SLOSH model is a mathematical and spatial model that estimates and models storm surge heights under different circumstances. The model uses a number of variables to define and compute storm surge potential and provides estimates of surge heights using temporal data for past, present, and theoretical hurricanes. These variables include storm size, wind speed, track, and pressure. Once these variables have been calculated in the model, it is then applied to a specific shoreline of the user’s choice, determined using a hydrologically- correct digital elevation model to account for rivers, roads, bathymetry, and other features. The output is a spatial grid that represents different surge levels for different scenarios. The National Hurricane Center provides inputs for the SLOSH model.
As shown on Figure 4-6, hurricane storm surge inundation can be expected to occur along portions of the Covell’s Beach route. This inundation is constrained to the southern portions of the route; no hurricane storm surge inundation would be expected at the proposed substation site. The heavily-insulated onshore export cable, which will be buried within an underground concrete duct bank, is designed to withstand wet conditions and would be unaffected by these scenarios.
4771.03/Vineyard Wind Connector 4-11 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. 4.4.4 Shoreline Change
Planned HDD installation of cable at the shoreline will result in a cable burial depth of over 30 feet at the current tideline. To ensure that the proposed onshore infrastructure will not be vulnerable to shoreline erosion, the Proponent performed a shoreline change analysis. Shoreline change at the Covell’s Beach Landfall Site is shown on Figure 4-7, which illustrates that since 1846 the shoreline has accreted approximately 150 feet. The HDD pit and transition vault at the Landfall Site would be in the paved parking lot, well back from the existing high waterline (see Figure 4-8). Based on this analysis, proposed infrastructure associated with the Covell’s Beach Landfall Site would be sufficiently set back from the shoreline.
As presented above, the proposed infrastructure associated with the transition vaults and manholes for the transition from offshore export cables to onshore export cables would be located sufficiently onshore that they would not be expected to be vulnerable to shoreline change over the life of the Project. Furthermore, the Project’s buried ductbank and export cables will comply with performance standards of the Massachusetts Wetlands Protection Act, and construction techniques will ensure the Project will not result in any impacts related to erosion at the Landfall Site.
4.5 Marine Resources
4.5.1 Offshore Cable Installation Impacts
Installation of the proposed cables is described in Section 3.1. Based on 2018 survey data and the preliminary cable alignments identified by the Company’s engineers, potential impact calculations are provided below in Table 4-2. As shown in Table 4-2, depending on the installation equipment used for cable installation (e.g., jet-plow, mechanical plow), the direct trenching impact area will vary between 1.3 and 3.3 feet (0.4 to 1 meter) in width. Approximately 6.9 miles of the Offshore Export Cable Corridor, including the length installed via HDD, is located within Barnstable County. In addition, the cable installation tool is expected to move along the seafloor on skids or tracks, which will have the potential to cause minor disturbance along a narrow strip between 3.3 and 6.6 feet (1 to 2 m) wide, although the functional impact is expected to be minor. Trenching for cable installation is expected to temporarily impact an area of approximately 5 acres. All impact calculations use the most conservative assumptions (see Table 4-2). Additional discussion of impact calculations associated with dredging, anchoring and cable protection follow.
4771.03/Vineyard Wind Connector 4-12 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Table 4-2 Offshore Export Cable Corridor Characteristics and Impacts from Installation of 2 Offshore Export Cables (Barnstable County waters)
Route to Covell’s Beach Total Length1 6.6 miles Volume of sand wave dredging2 1,000 – 1,500 cubic meters Trench impact zone3 5 acres Disturbance zone from tool skids/tracks4 11 acres Anchoring5 0.7 acres Cable Protection6 9 acres Hard bottom impacted by trenching7 0 Complex bottom impacted by trenching 0.1 acres (acres)70.1 1 1 mile = 0.87 nautical miles. Length excludes HDD (total length with HDD is approximately 6.9 miles). 2 The lower bounds of the range presented in the table are based on 2018 survey results; the upper bounds of the range include contingency to account for changes in sand wave features between the time of the 2018 survey and the time of cable installation and ongoing additional refinement of cable alignments within the installation corridor. Given the mobility and changing morphology of the sand waves, dredge volumes are provided rather than estimated length of dredging to reduce uncertainty. 3 Based on updated information from the Company’s engineers, depending on the installation equipment used for cable installation (e.g., jet-plow, mechanical plow,), the direct trenching impact area will vary between 1.3 and 3.3 feet (0.4 – 1 m) in width. The impact area provided in the table reflects the most conservative 3.3-foot (1-m) impact width. 4 Based on updated information from the Company’s engineers, depending on the installation equipment used for cable installation (e.g., jet-plow, mechanical plow, etc.), skids or tracks on the installation tool will have the potential to cause minor disturbance along an area between 3.3 and 6.6 feet (1-2m) wide, although the functional impact is expected to be minor. The impact area identified in the table reflects the most conservative 6.6-foot-wide (2-m) disturbance zone. 5 See Section 4.5.1.2. 6 As described below, although the Company’s priority is to achieve sufficient burial depth and avoid cable protection, a worst-case estimate is that up to 10% of the cable alignments may require cable protection measures. It is unlikely that cable protection will be needed in Barnstable County waters; however, to be conservative, since it is not possible to delineate exactly where this cable protection may be required, this impact calculation assumes all cable protection will occur in Barnstable County waters. If it is needed, the Company’s technical engineers have determined that cable protection would be approximately 10 feet (3 m) wide. 7 The Company’s engineers have defined preliminary cable alignments within the installation corridor to avoid and minimize impacts to complex bottom (the Project will not impact hard bottom, eelgrass, or core habitat of the North Atlantic Right Whale within Barnstable waters). These calculations are based on the length through complex bottom measured along the preliminary cable alignments. Cable alignments will continue to be refined based on ongoing evaluation of geological conditions in the surface and shallow subsurface, additional pre-construction surveys, and contractor input, and will reflect the dual priorities of minimizing impacts while maximizing the likelihood of successful installation.
4771.03/Vineyard Wind Connector 4-13 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. 4.5.1.1 Sand Wave Dredging
As described in Section 2.2.2, some pre-cable-laying dredging may be needed where large, active sand waves are present across certain portions of the Offshore Export Cable Corridor; this dredging may be needed to ensure sufficient cable burial beneath the stable seabed. Very little dredging is expected to take place in Barnstable waters. A conservative estimate of the amount dredging that may be required is a total corridor length of approximately 650 feet in length, an equivalent of up to approximately 1,500 cubic meters (2,000 cubic yards). Jetting and trailing suction hopper dredge (TSHD) are both under consideration as dredging methodologies, though TSHD is the anticipated methodology for dredging given the heights of sand waves in the Project area. Such dredging will result in an additional incremental impact relative to typical offshore export cable installation. Due to the dynamic nature of sand waves, driven by the strong tidal currents within Nantucket Sound, it is not possible to delineate exactly where these sand waves will be located when offshore export cable installation commences. Rather, at this time it is only possible to delineate the stretches of the Offshore Export Cable Corridor where dredging is anticipated due to conditions that suggest sand waves will be present; within Barnstable County waters, the estimated length of dredging is approximately 0.8 miles (1,265 m) (see Figure 2-3 in Section 2).
Where dredging is necessary through sand waves, the dredge cut will be approximately 65 feet (20 m) wide (measured at the bottom of the dredge cut) and centered on each of the two export cable alignments. Estimated impact areas within Barnstable County waters are shown in Table 4-2.
4.5.1.2 Anchoring
As described in Section 3.1.1, anchoring may be required along the entire Offshore Export Cable Corridor to enable the option of using these deeper penetration tools (see Figure 4-9).
The Company’s engineers estimate there would be approximately 108 square feet (10 m2) of disturbance from each anchor and associated anchor sweep (assuming an approximately 2.7- meter anchor), such that a vessel equipped with five anchors (four-point anchoring system plus a pull-ahead anchor) would disturb approximately 540 square feet (50 m2) per each anchoring set. Using the conservative estimate of approximately 6.6 miles of anchoring within Barnstable County waters, and assuming an anchored installation vessel may need to reposition every approximately 1,312 feet (400 meters) along that length, that vessel would reposition 27 times. Since two offshore export cables will be installed, impacts from anchoring could affect approximately 0.7 acres (29,160 square feet, or 0.003 km2) (540 ft2 x 27 anchoring sets x 2 cables) of Land Under the Ocean.
Organisms that may be subject to impacts from possible anchor line sweep include mollusks such as bay scallops, surf clams, whelks, and other sessile species, such as tube-dwelling polychaetes or mat-forming amphipods, which make up a relatively large portion of the taxa occurring in the area of the proposed action. Organisms that are mobile, such as certain
4771.03/Vineyard Wind Connector 4-14 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. polychaete species, amphipods, and crabs, may be able to avoid impacts from the anchor line sweep because sediment vibrations would cause avoidance behaviors as the cable laying equipment moves across the seafloor.1
4.5.1.3 Cable Protection
As described in Section 3.1.5, the Company’s priority will be to achieve sufficient burial depth of the two offshore export cables and to avoid the need for any cable protection. The Company’s engineers are maintaining a conservative estimate that up to 10% of the total cable alignments from the lease area in federal waters may require cable protection. The multiple and detailed offshore survey campaigns conducted by the Company indicate that in the waters in the jurisdiction of Barnstable County it is unlikely that any significant amount of cable protection will be necessary. Nonetheless, a conservative calculation of potential cable protection within Barnstable waters, based on a cable protection width of approximately 10 feet (3 m), is reflected in Table 4-2. Vineyard Wind is seeking to minimize the amount of cable protection required not only to avoid and minimize environmental impacts but also to reduce installation time and effort.
4.5.2 Marine Mammals
Marine mammals that may potentially occur in the portion of Nantucket Sound within Barnstable County include whales, dolphins, seals, or porpoises. The frequency and seasonality of marine mammal presence within Nantucket Sound varies by individual species, with species such as the larger whales only rarely identified within the portion of Nantucket Sound within Barnstable County. Marine mammals impacts and mitigation are also discussed in detail in Section 4.1 of the FEIR and 5.1 of the SDEIR, both of which are incorporated by reference.
Specific to the North Atlantic right whale (NARW), the best available science demonstrates that Nantucket Sound does not provide consistent habitat for NARWs, and during extensive multi-year surveys conducted by the Commonwealth of Massachusetts no NARWs were sighted in Nantucket Sound. Further, the Project is avoiding core habitat for the NARW, and the Massachusetts OMP does not map any core habitat for the species in Barnstable County waters.
While the presence of endangered marine mammals such as the NARW is extremely rare in areas subject to Commission review, best management practices (BMPs) and mitigation will be integrated with and applied to offshore construction and installation activities to meet or exceed the required standards of applicable statutes, regulations, and policies. In addition to state-level reviews, impacts to endangered species and marine mammals are
1 U.S. Department of Energy (USDOE), Minerals Management Service (MMS). 2009. Final Environmental Impact Statement for the Proposed Cape Wind Energy Project, Nantucket Sound, Massachusetts (Adopted), DOE/EIS-0470. Retrieved from https://www.boem.gov/Cape-Wind-FEIR/.
4771.03/Vineyard Wind Connector 4-15 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. comprehensively reviewed at the federal level under both the Endangered Species Act (ESA) and the Marine Mammal Protection Act (MMPA). The ESA review is conducted by BOEM in consultation with resource agencies (U.S. Fish and Wildlife Service [USFWS] for avian species and National Marine Fisheries Service [NMFS] for marine mammals). These reviews are in addition to the National Environmental Policy Act (NEPA) review, pursuant to which BOEM will produce both Draft and Final Environmental Impact Statements that will cover all environmental concerns. In addition, Vineyard Wind has applied for an Incidental Harassment Authorization (IHA) with a separate division of NMFS. The above-described processes will result in the final mitigation measures to be implemented for these important species. The final mitigation measures will be informed by input from Massachusetts State Agencies as well as environmental non-governmental organizations (eNGOs)2. The discussion below includes mitigation that is under review for the overall Project, in state and federal waters, through the above-described processes.
NOAA Fisheries, also known as the NMFS, has responsibility for implementing the MMPA and is specifically responsible for the protection of whales, dolphins, porpoises, seals, and sea lions. While overseen by a federal agency, the MMPA is not limited to federal waters. Instead, the scope of the MMPA is to provide protection to all marine mammals regardless of location.
Vineyard Wind is in the middle of extensive, ongoing consultations with BOEM and NMFS to define the most appropriate mitigation measures to protect marine mammals during the different phases of construction. These consultations have addressed activities in federal waters (such as pile driving) but have also included activities in state waters (such as construction vessel transit and cable laying). Working with BOEM and NMFS, Vineyard Wind has identified a suite of mitigation measures that include time-of-year (TOY) restrictions for pile driving (an activity only proposed in federal waters) and techniques such as Passive Acoustic Monitoring (PAM), as well as other monitoring options such as aerial- or vessel- based visual observers. Vineyard Wind, BOEM, and NMFS expect ongoing consultations over the seven to ten months will lead to the final specification of the multiple mitigation measures that are expected to be used to protect marine mammals.
The Company believes that adequate protection of marine mammals is best addressed through the MMPA process and with the marine mammal experts at NMFS and BOEM, who will specify the most appropriate mitigation measures for protection of all marine mammals.
Vineyard Wind has also been in consultations with various environmental advocacy organizations. Consultation with environmental non-governmental organizations (NGOs) has been extensive and ongoing on a recurring basis since mid-2017, and many of the
2 eNGOs include environmental organizations that have been active in offshore wind development in Massachusetts including, but not limited to, Conservation Law Foundation, National Wildlife Federation, Natural Resources Defense Council, and Massachusetts Audubon Society.
4771.03/Vineyard Wind Connector 4-16 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. mitigation measures proposed to NMFS and BOEM were derived from these consultations. Mitigation measures proposed to reduce potential acoustic and non-acoustic impacts during construction and operations have been included in the Company’s Construction and Operations Plan (COP); the proposed monitoring and mitigation plans for construction and operations are shown in Table 31 of the COP available at https://www.boem.gov/Vineyard- Wind/. On January 22, 2019, Vineyard Wind and the National Wildlife Federation, the Natural Resources Defense Council, and the Conservation Law Foundation entered into a historic agreement pertaining to a comprehensive suite of protections for NARW. A copy of this agreement is attached as Attachment M. As part of this agreement, Vineyard Wind’s project plan adopts restrictions, primarily for work in federal waters, beyond those required by law, on vessel speed and limits loud turbine construction from pile driving and geophysical survey activities to times when NARW are unlikely to be in the area.
Additionally, as described in Section 2.5.2.1, as part of the $15 million Offshore Wind Accelerator commitment, Vineyard Wind has allocated $3 million to a “Wind and Whales” fund to help advance marine mammal protections as the offshore wind industry develops along the East Coast. The Wind and Whales Fund will support development and demonstration of innovative methods and technologies to enhance protections for marine mammals as the Massachusetts and U.S. offshore wind industries continue to grow. Vineyard Wind is actively working with Massachusetts marine mammal experts and other relevant parties to build a framework for how funds will be allocated. The Fund represents an investment in the development and demonstration of innovative methods and technologies to enhance protections for marine mammals generally as the offshore wind industry continues to grow in the region.
4.5.3 Fisheries, Fish Habitat
This section discusses fisheries resources in Barnstable County. By way of background, Sections 1.0, 3.1, 3.2, and 5.4 of the SDEIR and Section 3.0 of the FEIR provide additional information on commercial and recreational fisheries in state waters. In addition to state- level reviews, impacts to fisheries resources are comprehensively reviewed at the federal level through the NEPA process, pursuant to which BOEM has produced a DEIS and will produce an FEIS that will cover impacts in both federal and state waters.
Due to the temporary nature of cable installation activites, the potential for impact to fisheries and fish habitat within Barnstable County waters is very limited.
4.5.3.1 Affected Environment
The following section summarizes the affected environment as it relates to commercial and recreational fisheries in the state waters of Barnstable County. The affected environment is described with additional detail in both the DEIR and the FEIR.
4771.03/Vineyard Wind Connector 4-17 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Shellfish Resources
Massachusetts cities and towns manage the shellfisheries in all waters within their boundaries that are not closed by the DMF for public health or other reasons, with the exception of the commercial harvest of Surf Clams and Ocean Quahogs that remain under state control. DMF has identified shellfish suitability habitats for the ten species of commercial shellfish listed in the Massachusetts Wetlands Protection Act Regulations (310 CMR 10.34). Mapped shellfish habitat in the Barnstable County include areas within Nantucket Sound (surf clam and bay scallop. Figure 4-10 illustrates these mapped shellfish habitats. Shellfish suitability habitat mapping represents represent potential habitat areas, although these areas may not currently support any shellfish. As can be seen in Figure 4-10, the proposed corridor does not cross through any mapped shellfish habitats.
Commercial Fishing Activity in Barnstable County Waters of the Cable Corridor
Many factors, both environmental and regulatory, contribute to productive commercial fishing areas, and as a result, the location of commercial fishing effort, and to a lesser extent for-hire recreational fishing activities, are variable. Fisheries not active during construction and installation, for example, are unlikely to be affected by cable installation activities, as would be the case during a seasonal or other closure.
4.5.3.2 Turbidity
While cable installation activities will result in some temporary elevated turbidity and localized sediment dispersion in the water column, the sediment which is briefly fluidized by the cable installation tool will quickly resettle in the trench. The Proponent engaged Swanson Environmental Associates and RPS to perform a sediment dispersion modeling study of offshore cable installation activities. That study was performed in support of the Vineyard Wind project’s federal permitting process led by BOEM and was included as a technical appendix to the Company’s Construction and Operations Plan (COP). As a result, the study includes some areas outside of state jurisdiction, such as those related to the inter-array cables proposed within the Wind Development Area (WDA) in federal waters. Nonetheless, the study in its entirety was provided as Attachment H of the DEIR, which the CCC has received and is part of the record for this DRI.
Two sediment deposition thresholds were selected for the analysis of potential impacts based upon biological significance to summarize the data: area of deposition greater than 1 mm thick, and area of deposition greater than 20 mm thick.
♦ A deposition thickness of 1 mm is the sensitivity threshold for demersal eggs (species with demersal eggs include Atlantic Wolffish, Atlantic Herring, Winter Flounder, Longfin Inshore Squid, and whelk species) and is based upon findings that Winter Flounder eggs, which have some of the smallest and most sensitive demersal eggs,
4771.03/Vineyard Wind Connector 4-18 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. maintain hatching success with 1 mm of deposition3. Depending on the TOY restrictions applied to the Project, it is possible that demersal eggs of all or some of the listed species may not be present and that this conservative threshold may not be applicable.
♦ A deposition thickness of 20 mm is the sensitivity threshold for shellfish.
The modeling demonstrates that deposition greater than 20 mm will only result from the dumping activities by the trailing suction hopper dredge (TSHD). Dredging will only occur within mobile sand waves, and dumping from the TSHD will also only occur within areas of mobile sand waves, which are less suitable shellfish habitat. Furthermore, no areas of deposition greater than 20 mm will result from typical cable installation activities (e.g., jet- plow, mechanical trencher). Therefore, sediment deposition from cable installation is not anticipated to affect shellfish.
The plume from jet-plow installation as delineated by excess suspended sediment concentrations greater than 10 mg/L typically extended less than 656 feet (200 m) from the route centerline, though did extend up to ~1.2 miles (~2 km) in some places. Further, the excess concentrations were confined to the lower portion of the water column and resettled rapidly (within 4-6 hours) due to the high proportion of coarse sand throughout the route. Therefore, these concentrations and durations of exposure are below those causing sublethal or lethal effects to benthic organisms. Simulations of cable installation, both with and without jetting for sand wave clearance, using typical installation parameters showed that deposition greater than 1 mm occurred within 262-328 feet (80-100 m) of the route centerline.
4.5.3.3 Fisheries Communication Plan
To avoid and minimize disruptions to commercial and recreational fishing activities, Vineyard Wind will implement a comprehensive communications plan with the various port authorities, federal, state, and local authorities, and other key stakeholders, including recreational fishermen and boaters, commercial fishermen, harbormasters, the marine pilots, and other port operators.
Commercial and recreational fishermen will be notified, as described in the Fisheries Communication Plan, of all the location and duration of all planned cable installation activities. The Project management team will continue to develop and utilize communications plans to ensure relevant and accurate information regarding the Project is disseminated to the various commercial fishing communities during each stage of the Project.
3 Berry, W.J., Rubinstein, N.I., Hinchey, E.H., Klein-MacPhee. G, & Clarke, D.G. (2011). Assessment of dredging-induced sedimentation effects on Winter Flounder (Pseudopleuronectes americanus) hatching success: results of laboratory investigations. Proceedings of the Western Dredging Association Technical Conference and Texas A&M Dredging Seminar, Nashville, Tennessee, June 5-8, 2011. Retrieved from http://nerdt.org/wpcontent/uploads/2014/12/WEDA_Berry.pdf
4771.03/Vineyard Wind Connector 4-19 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. As noted in Section 3.1.4, post-installation monitoring through the Project’s Benthic Habitat Monitoring Plan and ongoing partnerships with research and other organizations will be conducted to document habitat disturbance and recovery. A draft Fisheries Communication is provided as Attachment I, and the document will continue to evolve to reflect ongoing planning and coordination with stakeholders.
In addition, Vineyard Wind will implement a comprehensive communications plan with the various port authorities, federal, state, and local authorities, and other key stakeholders, including recreational fishermen and boaters, commercial fishermen, harbormasters, the marine pilots, and other port operators.
4.5.3.4 Pre- and Post-Construction Fisheries Monitoring Plan
Vineyard Wind is implementing the framework for pre- and post-construction fisheries monitoring programs to measure the Project’s effect on fisheries resources and is working with SMAST and local stakeholders to inform that effort and design the study. The duration of monitoring is being determined as part of the initial effort to determine the scope of the studies and is anticipated to include the pre-construction period and at least one year of post- construction monitoring.
In the past two months, SMAST has hosted four workshops (including one in Chatham on November 19) with the region’s fishing industry to identify priorities for assessments of impacts on fisheries and ecological conditions that are associated with offshore wind development. These priorities, which focus on effects before, during, and after construction, will be used to aid the design of studies regarding the Vineyard Wind project, which will be the nation’s first utility-scale offshore wind project. Vineyard Wind is continuing outreach to additional stakeholders in the fishing community to solicit input on the scope the studies.
Fisheries Impacts Assessment Protocol
As described above, the comprehensive research effort will be a valuable tool for assessing impacts of offshore wind development on commercial and recreational fisheries. Vineyard Wind will continue to work with the region’s fisheries interests to identify research priorities that will inform the design and effort of studies to evaluate Project-related impacts. This is intended to be a collaborative process that relies on the input of both commercial and recreational fisheries interests as well as scientists and regulators.
Lobster Settlement Study
Vineyard Wind has been consulting with DMF staff to design appropriate lobster studies to determine potential impacts on adult and juvenile lobsters. After reviewing the geophysical and geotechnical data with DMF, it was suggested that there may not be appropriate habitat to conduct a lobster settlement study. Therefore, the focus will likely be on the adult lobster
4771.03/Vineyard Wind Connector 4-20 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. population. Vineyard Wind will continue working with DMF, and other experts, in developing appropriate study methodologies and locations for those studies.
Studies Using Existing Data
To supplement the pre- and post-construction monitoring plan, the Company will utilize existing data sources such as the NEFSC spring and fall bottom trawl survey which has a time series dating back to 1963 and includes abundance estimates for commercially important species as well as digitally recorded bottom temperature data starting in 1971 at select sampling locations. Other existing data in the Wind Development Area that could be incorporated into the plan include a drop camera survey performed in 2012 and 2013 to count benthic species and identify bottom types from still images. The drop camera survey was funded through MassCEC and was carried out by SMAST. Other existing data are from three industry-based surveys for yellowtail founder in southern New England. Rhode Island Division of Fish and Wildlife completed two surveys in 2003 and 2005, and SMAST completed one in 2011. The purpose of the surveys was to examine the abundance, distribution, and biological characteristics of yellowtail flounder in southern New England.
Information collected by Vineyard Wind will be publicly available to inform future offshore wind permitting and public policy decisions.
4.5.3.5 Mitigation
Construction and installation activities will occur within very limited and well-defined areas of the cable corridor and Project-related impacts to finfish and invertebrates targeted by commercial and recreational fishermen within state waters, including Barnstable County, are expected to be short-term and localized during construction and installation phases. Within state waters, including all of Nantucket Sound, vessel restrictions are not proposed other than those imposed in coordination with the USCG in the immediate vicinity of construction and installation work. The anticipated cable installation timeframe is described in Section 4.1.2 of the SDEIR and Section 4.5.4, below.
After further consultation with staff from DMF’s Shellfish and Habitat Programs, MassDEP, CZM, and local fishermen, Vineyard Wind anticipates finalizing any necessary mitigation for the Project during the 401 Water Quality Certificate (WQC) and Chapter 91 License permitting process. Mitigation for the entire Vineyard Wind project is being addressed through the federal permitting process.
The Project continues to evaluate mitigation for any unavoidable impacts to commercially- important species in Nantucket Sound. Vineyard Wind has communicated with stakeholders from the Nantucket Sound lobster and whelk fishery and, as an important sector of Nantucket Sound fisheries, prioritizes coordination with this group. During the Company’s on-going communication and outreach efforts, fixed gear fishermen have expressed concerns about the potential for interaction between fixed gear and survey vessels. To address these concerns
4771.03/Vineyard Wind Connector 4-21 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. and so that the Company quickly addresses gear interaction and/or damage from Project vessels, the Company’s Fishery Communication Plan includes a Fixed Gear Interactions Protocol that outlines procedures should interaction between a survey or construction vessel and fixed gear occurs. As part of this protocol, the buoy permit number and color are logged by the survey vessel crew and communicated to the Company’s Fisheries Liaison who then identifies the gear owner from the fishing permit lists and follows up with the gear owner.
A compensatory mitigation plan for gear loss is anticipated to be included in the ongoing work with DMF and the Massachusetts Fisheries Working group. Regardless of the program used, Vineyard Wind is committed to ensuring gear loss is addressed efficiently and fishermen are compensated as discussed in the Fisheries Communication Plan. In accordance with the final gear loss plan, Vineyard Wind will compensate fishermen appropriately for gear loss if/when it occurs.
Lost fishing time is being addressed in a comprehensive mitigation plan being developed in support of the federal NEPA review process and in coordination with Massachusetts and Rhode Island agencies, and other regional stakeholders. Vineyard Wind is committing to include funding for regional fisheries studies as part of such mitigation, if there is consensus to do so among stakeholders.
Squid vessel activity occurs within Nantucket Sound waters. Through the NEPA process, BOEM is considering a Dynamic Squid Fishing Avoidance Plan that would require daily communication between squid fishery representatives and Vineyard Wind so that harvesters are aware of the day’s activities and the developer is aware of where fishing is occurring. Vineyard Wind would support implementation of such a plan.
Based on feedback from stakeholders, including commercial fishing interests, Vineyard Wind is developing a program to manage fishing-specific communications regarding Project activities and impacts. It is anticipated that the program will provide a single point-of-contact for fishermen to report problems and concerns with construction and installation activities and to report gear loss or damage from project components and activities. Vineyard Wind will also implement offshore markings such as high flyer buoys, as appropriate, and downloadable electronic information of project activities for chart plotters.
Vineyard Wind remains committed to continued communication and coordination with fisheries interests.
4.5.4 Time of Year Restrictions
There is discussion of TOY restrictions in Section 3.4 of the FEIR. Vineyard Wind has convened a series of meetings with state and federal agencies to address the timing of export cable installation and potential TOY restrictions. Meeting attendees have included representatives from BOEM, NMFS, Massachusetts CZM, DMF, MassDEP, and NHESP. The
4771.03/Vineyard Wind Connector 4-22 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. first of these meetings took place on July 24, 2018, and the second meeting took place on August 27, 2018.
During the meetings, Vineyard Wind reviewed two critical schedule considerations for the Project:
1. Safe operating conditions for cable-laying vessels. Cable-laying vessels can only safely operate in certain wave conditions. To ensure the welfare of the vessel and its crew, Vineyard Wind can only conduct cable-laying if there is a greater than 50% probability of obtaining the required weather conditions during the installation activity. An extensive analysis of historic weather conditions indicates it is statistically likely to obtain safe weather conditions for cable-laying during the period of approximately April to September. Scheduling work within safe weather conditions is critical for the Project because, if weather conditions exceed the limiting operational conditions for the cable and safe working limits for the vessel, then the crew may have to undertake a controlled abandonment of the cable, whereby the cable will be cut and placed on the seabed so the vessel can seek refuge. In this instance, the cable would then have to be spliced. Such a repair joint would take approximately six days to complete, which would then seriously compromise the progress of the operation since it would require a favourable weather window both for the repair joint and the remaining cable-laying activity.
2. Sequencing the Project to deliver power by the end of 2021. Offshore export cable installation is part of the critical path for power production and must be completed by May to June of 2021, so that the time- and resource-intensive process of WTG commissioning (which is partially dependent on having power from the offshore export cable(s)) can start in the late summer and power can be delivered by the end of 2021. Delays in cable installation would delay the delivery of carbon-free energy, as well as the estimated $1.4 billion in ratepayer savings.
Consideration of the safe operational conditions for cable-laying vessels and the need to provide power at a competitive rate by the end of 2021 has led Vineyard Wind to identify the period of April to June as the preferred offshore export cable installation timeframe.
Vineyard Wind and attendees at the TOY meetings also reviewed potential environmental considerations from cable-laying activities. Both NMFS and DMF identified that a potential TOY along the Offshore Export Cable Corridor may be desirable to protect squid mops and squid fishing activity during the spring and summer months; these are the same months when
4771.03/Vineyard Wind Connector 4-23 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. the weather conditions are most suitable for cable-laying.4 Vineyard Wind provided an analysis of modelled sediment deposition from offshore export cable installation and concluded that export cable installation would impact less than 1% (per cable) of mapped areas where longfin squid egg bycatch had been observed in bottom trawls.
Vineyard Wind acknowledges the concerns from the agencies, and in particular DMF’s comment letter on the SDEIR, stating a preference for cable laying within Nantucket Sound during the months of July and August instead of April and May. As stated by DMF: “For Nantucket Sound, cable laying in July and August instead of April and May avoids a more sensitive time of year for a wide array of natural resources that are actively reproducing and settling in the springtime. The springtime is also the period of commercial squid activity, which is very active across parts of the cable route. The squid fishery closes on June 10 in state waters and the Nantucket Sound donut hole, which is under state fisheries jurisdiction.”
As noted above, Vineyard Wind has identified the period of April to June as the preferred offshore export cable installation timeframe for safety reasons and to ensure power delivery at a competitive rate by the end of 2021. Nevertheless, Vineyard Wind is committed to fully evaluating all options to allow it to avoid all or most cable-laying activities within Nantucket Sound during the months of April and May identified by DMF as a more sensitive time of year. Vineyard Wind has engaged with multiple cable suppliers and is evaluating several options, including cable manufacturing schedules and potential timeframes for earlier cable delivery. Vineyard Wind is also reviewing its probabilistic weather modelling and evaluating whether the Company could accept more weather-related risk in the earlier spring months without compromising the health and safety of the cable-laying vessel and crew. Vineyard Wind expects to make substantial progress on these evaluations over the coming months and would expect that definitive TOY restrictions could be worked out during the state permitting processes, particularly the 401 Water Quality Certification.
Although the final TOY discussion is still underway, the Company is committed to the following TOY restrictions:
♦ HDD activities at the Covell’s Beach Landfall Site will begin in advance of April 1, or will not begin until August 31, to avoid and minimize noise impacts to Piping Plover during the breeding season; and
4 DMF also noted that no TOY is needed at Covell’s Beach, as the proposed HDD will avoid impacts to horseshoe crab spawning habitat. At the alternative New Hampshire Avenue Landfall Site, DMF identified a need for TOYs from January 15 to October 30 to protect resources such as winter flounder and shellfish. Vineyard Wind’s preliminary analysis indicates it may be feasible to install a nearshore section of submarine cable in fall 2020, outside of the recommended TOY restriction.
4771.03/Vineyard Wind Connector 4-24 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. ♦ No pile-driving (an activity only proposed within federal waters) will take place from January 1 to April 30 to avoid and minimize impacts to turtles, whales (including the North Atlantic Right Whale), and other marine mammals.
4.6 Open Space and Recreation
The Project will enhance the recreational area at Covell’s Beach through construction of a new bathhouse and will also resurface the beach parking lot. Access to the beach via the Covell’s Beach parking lot will be maintained throughout construction (a portion of the parking will stay open throughout construction). Construction will be conducted during the off-season when use of the parking lot is low.
The Project will impact no other open space or recreational areas.
4.7 Transportation
4.7.1 Onshore Transportation Management
The Project’s transportation-related impacts will be limited to the construction period when temporary lane closures will be required. Construction of the onshore duct bank is expected to progress at a rate of 100 to 200 feet per day, so any location would be affected for only a short period of time. Police details and other appropriate traffic management measures will be used to maintain traffic flow, and traffic management will always be coordinated with Town officials.
Prior to construction, the Proponent will work closely with the Town of Barnstable to refine appropriate TMPs for minimizing construction-period traffic disruptions. The TMPs will be submitted for review and approval by appropriate municipal authorities (typically DPW/Town Engineer and Police). Draft TMPs are included with the Engineering Plans in Attachment E. These plans are an iterative process and will continue to evolve as the Proponent works with state and local officials and community residents to minimize impacts to the surrounding communities.
The Company will continue to work closely with the Barnstable Police Department and DPW, and with MassDOT District 5 traffic engineers to develop a series of temporary traffic control plans to address local traffic impacts related to the Project. During construction, traffic management will ensure safe and efficient flow approaching and traveling through work zones. To the extent feasible, management measures will be implemented to minimizes delays, congestion, and increases to travel time due to construction activities. The Proponent continues to evaluate traffic volumes along the route, traffic alternatives, and constructability requirements in consultation with traffic engineers, construction and Project engineers, and state and municipal officials.
The draft TMP includes the following mitigation measures:
4771.03/Vineyard Wind Connector 4-25 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. 1. Use of Advanced Warning Signs and Changeable Message Boards to alert motorists of “Road Work Ahead” and Alternate Routes.
2. Use of Construction Signage to alert motorists of construction activities in the “Work Zone”.
3. Use of One Lane Road (Bi-directional) traffic control with police details in the “Work Zone”.
4. Use of Detour plans around the “Work Zone” for short-duration road closures during daylight construction activities.
5. Use of Traffic Control Devices such as traffic cones, reflectorized drums, barricades and temporary pavement markings for delineation of travel ways and walkways.
6. Use of defined hours of operation to limit the length of trench the contractor may have open at any given time and to regulate construction during weekends and holidays.
7. Use of Road Plates to cover trench work in progress to restore two-way traffic during non-working hours or to allow access to local streets and driveways.
8. Use of Designated Staging and Laydown Areas to minimize impacts to pedestrian and vehicular traffic.
9. Use of public communications media to inform the public of current and future construction activities and how they may affect local traffic conditions.
The above-mentioned traffic mitigation measures will be performed in accordance with the Manual of Uniform Traffic Control Devices (2009 Edition) and the MassDOT Work Zone Safety Guidelines. For additional detail on the TMP, please refer to Sheets 18 through 24 of the engineering plans in Attachment E.
Table 4-3 below identifies TMP mitigation measures to be applied to construction along the Covell’s Beach Route.
4771.03/Vineyard Wind Connector 4-26 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Table 4-3 TMP mitigation measures along the Covell’s Beach Route
Construction Street or Route From To TMP Action Plan Estimated Traffic Impacts5 Activity Craigville Lake Elizabeth Centerville 10’wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Utility work road Approximate 20-day construction Beach Road Drive Avenue Local detour 1: Lake Elizabeth to duration Centerville Number of homes/businesses 1 Police detail impacted: 13 Craigville Centerville Strawberry Hill 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Splice vault road Approximate 9-day construction Beach Road Avenue Road Utility work Local detour 1: Centerville Ave to Old duration Craigville Rd Number of homes/businesses 1 police detail impacted: 7 Strawberry Hill Craigville Old Craigville 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Utility work road Road Beach Road Road Approximate 24-day construction Local detour 1: Craigville Beach Rd to duration Centerville Ave to Old Craigville Rd Number of homes/businesses 1 police detail impacted: 22 Strawberry Hill Old Craigville Old Town Road 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Utility work road Road Road Approximate 14-day construction Local detour 1: Old Craigville Rd to Old duration Town Rd Number of homes/businesses 1 police detail impacted: 20 Strawberry Hill Old Town Pine Street 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Splice vault road Road Road Approximate 11-day construction Utility work Local detour 1: Old Town Rd to Old duration Craigville Rd to W Main St to Pine St Number of homes/businesses 1 police detail impacted: 16
5 Construction duration is based on a conservative rate for construction advancement of 100 feet per day.
4771.03/Vineyard Wind Connector 4-27 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Table 4-3 TMP mitigation measures along the Covell’s Beach Route (Continued)
Construction Street or Route From To TMP Action Plan Estimated Traffic Impacts6 Activity Strawberry Hill Pine Street W Main Street 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Road Splice vault road Approximate 14-day construction Utility work Local detour 1: Pine St to W Main St duration 1 police detail Number of homes/businesses impacted: 20 Strawberry Hill W Main Street 100 feet south 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Road of Falmouth Rd Utility work road Approximate 11-day construction (Route 28) Local detour 1: W Main St to Rte 28 duration 1 Police detail Number of homes/businesses impacted: 15 Strawberry Hill 100 feet south Wequaquet 10’ wide trenching One lane closure Night Work Road of Falmouth Lane Drainage Work Two-way traffic Approximate 6-day construction Rd (Route 28) Utility work Set signal on flash duration Local detour 1: W Main St to Rte 28 Number of homes/businesses 2-3 Police detail impacted: 4 Strawberry Hill Wequaquet Phinneys Lane 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Road / Lane Splice vault road Approximate 18-day construction Wequaquet Utility work Local detour 1: Rte 28 to Phinneys Ln duration Lane 1 Police detail Number of homes/businesses impacted: 18 Phinneys Lane Wequaquet Old Strawberry 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Lane Hill Road Splice vault road Approximate 40-day construction Utility work Local detour 1: Rte 28 to Old Strawberry duration Hill Rd Number of homes/businesses 2 Police detail impacted: 26
6 Construction duration is based on a conservative rate for construction advancement of 100 feet per day.
4771.03/Vineyard Wind Connector 4-28 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Table 4-3 TMP mitigation measures along the Covell’s Beach Route (Continued)
Construction Street or Route From To TMP Action Plan Estimated Traffic Impacts7 Activity Phinneys Lane Old 100 feet south 10’ wide trenching Road closed/Local traffic only. One-lane Work during off-peak hours Strawberry of Iyannough Splice vault road Approximate 16-day construction Hill Road Rd (Route 132) Utility work Local detour 1: Old Strawberry Hill Rd duration to Rte 132 Number of homes/businesses 2 Police detail impacted: 15 Phinneys Lane At Iyannough 10’ wide trenching Half-roadway closure eastbound Night Work Rd (Route Utility work Two-way traffic Approximate 2-day construction 132) (south) Set signals on flash duration 2 police detail Number of homes/businesses Taper 2 lanes to 1 at intersection impacted: 0 Phinneys Lane At Iyannough 10’ wide trenching Half-roadway closure westbound Night Work Rd (Route Utility work Two-way traffic Approximate 2-day construction 132) (north) Set signals on flash duration 2 police detail Number of homes/businesses Taper 2 lanes to 1 at intersection impacted: 0 Phinneys Lane 100 feet north Attucks Lane 10’ wide trenching Local detour 1: Rte 132 to Bearses Way Night Work of Iyannough Utility work to Attucks Ln Approximate 4-day construction Rd (Route Local detour 2: Rte 132 to Attucks Ln duration 132) 2 Police detail Number of homes/businesses impacted: 0 Phinneys Lane At Attucks 10’ wide trenching Two-way traffic Night Work Lane Utility work Set signal on flash Approximate 3-day construction 2 Police detail duration Staging Number of homes/businesses 1. Right Eastbound lane closed impacted: 0 2. Eastbound left-turn lane; Westbound left-turn and left through lane closed 3. Right Westbound lane closed
7 Construction duration is based on a conservative rate for construction advancement of 100 feet per day.
4771.03/Vineyard Wind Connector 4-29 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Table 4-3 TMP mitigation measures along the Covell’s Beach Route (Continued)
Construction Street or Route From To TMP Action Plan Estimated Traffic Impacts8 Activity Attucks Lane Phinneys Lane Independence 10’ wide trenching Half-roadway closure. Two-way traffic Work during off-peak hours Drive in median Local detour 1: Rte 132 to Approximate 36-day construction Splice vault Independence Dr. duration Utility work 2 police detail Number of homes/businesses impacted: 3 Attucks Lane At 10’ wide trenching Two-way traffic Night Work Independence Utility work Set signal on flash Approximate 2-day construction Drive 2 Police detail duration Staging Number of homes/businesses 1. Two right Southbound lanes impacted: 0 closed 2. Two left Southbound lanes closed Independence Attucks Lane Barnstable 10’ wide trenching Half-roadway closure. Two-way traffic Work during off-peak hours Dr. Substation in median Local detour 1: Breeds Hill Rd to Approximate 53-day construction access road Splice vault Independence Dr. duration Utility work 2 Police detail Number of homes/businesses impacted: 10
8 Construction duration is based on a conservative rate for construction advancement of 100 feet per day.
4771.03/Vineyard Wind Connector 4-30 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. 4.7.2 Marine Navigation and Transportation
This section describes the maritime navigation and vessel traffic characteristics of Project- related activities as they may impact navigation and vessels operating to and from ports along the south coast of Massachusetts, Cape Cod, and the Islands. Vineyard Wind is not proposing any restrictions on navigation, fishing, or the placement of fixed or mobile fishing gear; however, construction and installation activities may temporarily affect navigation and/or fishing activities in the vicinity of construction and installation vessels. These impacts are temporary in nature and largely limited to the Project’s construction and installation period. The Project schedule is described in Section 2.6.
Vineyard Wind has developed a detailed Navigational Risk Assessment for the Project. The Navigational Risk Assessment conforms to the USCG guidance for Offshore Renewable Energy Installations contained in Navigation Vessel Inspection Circular 02-07, and incorporates information obtained through consultation with the USCG and numerous marine trades and maritime transportation stakeholders.
During the construction and installation phase, Vineyard Wind will employ a Marine Coordinator to manage all construction vessel logistics and act as a liaison with the USCG, port authorities, state and local law enforcement, marine patrol, and port operators. The Marine Coordinator will keep informed of all planned vessel deployment and will manage the Project’s marine logistics and vessel traffic coordination between the staging ports and the Wind Development Area in federal waters. Vineyard Wind has also engaged with the Northeast Marine Pilots Association to coordinate construction and installation vessel approaches to the Project region, as required by state and federal law, and to minimize impacts to commercial vessel traffic and navigation.
Vineyard Wind has been actively engaged with fisheries stakeholders for the past several years and has developed a Fisheries Communication Plan, which will continue to be refined throughout the Project. As described in the Fisheries Communication Plan, both a Fisheries Liaison and Fisheries Representative will be employed by Vineyard Wind to ensure effective communication and coordination between the Project and the fishermen. The Fisheries Communications Plan is provided in Attachment I; outreach to stakeholders, including fisheries groups, is discussed in Section 2.8.2.
Vineyard Wind is developing a framework for a pre- and post-construction fisheries monitoring program to measure the Project’s effect on fisheries resources. Vineyard Wind is working with the University of Massachusetts Dartmouth School for Marine Science and Technology (SMAST) and local stakeholders to inform that effort and design the study. The duration of monitoring will be determined as part of the initial effort to determine the scope of the study, but it is anticipated to include the pre-construction period and at least one year of post-construction monitoring.
4771.03/Vineyard Wind Connector 4-31 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Vineyard Wind will continue to distribute Notices to Mariners to notify recreational and commercial vessels of their intended operations related to both the offshore Wind Development Area in federal waters as well as the Offshore Export Cable Corridor. Local port communities and local media will be notified and kept informed as the construction and installation process progresses. Vineyard Wind is currently providing and will continue to provide portable digital media with electronic charts depicting locations of Project-related work to provide fishermen with accurate and precise information on work within the offshore Project area. The Project website will be updated regularly to provide information on the construction zone, scheduled activities, and specific Project information.
Additional information on marine transportation can be found in Section 4 of the SDEIR.
4.8 Economic Development
The Project is expected to create a range of environmental and economic benefits for southeastern Massachusetts (including New Bedford, the Cape, and the Islands), Massachusetts as a whole, and the entire New England region. Project benefits will extend across the design, environmental review, and permitting phase, the procurement, fabrication, and construction/commissioning phase, the multi-decade operating phase, as well as the future decommissioning effort. The Project is expected to generate numerous economic benefits across Massachusetts and the entire New England region. Economic benefits from the Project will be realized throughout the preconstruction, construction, operations and maintenance, and decommissioning phases. The Project’s extensive economic benefits are more fully described in Section 2.5 of the Application.
4.9 Heritage Preservation
The Project is subject to review by the MHC in compliance with M.G.L. Chapter 9, Sections 26-27C as amended by Chapter 254 of the Acts of 1988 (950 C.M.R. 71.00) known as “State Register Review”, and Section 106 of the National Historic Preservation Act. The Company undertook a cultural resource investigation to identify historic and archaeological resources adjacent to the Project. Historic Resources include properties listed or eligible for listing on the National Register of Historic Places, properties on the Massachusetts State Register of Historic Places, and properties included in the Inventory of Historic and Archaeological Assets of the Commonwealth (Inventory). Historic resources located along the Covell’s Beach route are shown on Figure 4-11.
4.9.1 Onshore Activities
Cable installation will largely be constructed in previously disturbed areas (i.e., within public roadways). All of the public roadway areas have been modified by construction of the road itself as well as above- and below-grade utilities, and it is unlikely that natural/undisturbed soils or potentially significant archaeological deposits would be located below or immediately adjacent to them. Based on an archaeological sensitivity assessment performed
4771.03/Vineyard Wind Connector 4-32 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. by the Proponent’s archaeology consultant, PAL, most of the upland route has been classified as having moderate sensitivity for archaeological resources along with isolated sections of low and high sensitivity.
Construction and operation of the Project will not affect any historic buildings or structures in along the proposed route. The proposed route passes by or through one Inventory Area and six Inventory properties, including four archaeological sites. Since the export cables will be underground, they will have no visual impacts to historic properties. In addition, the proposed substation will be too far distant from historic properties through intervening trees and structures to create any adverse visual effects.
A reconnaissance-level survey final report was provided to MHC on September 18, 2018 responding to MHC’s comments on a previous draft submitted in June 2018. MHC also issued an archaeological permit for an intensive-level survey on September 28, 2018, and the survey on the substation site was completed on November 2, 2018. The survey was completed in cooperation with local historical commissions and THPO. Public Archaeology Lab (PAL) did not recommend further testing. Potential effects, if any, to archaeological resources will be addressed with the MHC through Section 106 and the State Register Review processes.
4.9.2 Offshore Activities
In 2017, Gray & Pape Inc. was contracted by Vineyard Wind to provide archaeological support for high-resolution geophysical marine surveys and subsequent geotechnical activities along the potential Offshore Export Cable Corridors. This research was conducted in conjunction with Alpine Ocean Seismic Surveys Inc. and Fugro Marine Geoservices, Inc. These surveys continued in 2018 focused on the single proposed Offshore Export Cable Corridor.
Archival and document research and field investigations were conducted as part of the cultural resource examination, and background research included a review of historic documents, previous research reports, a site file check, shipwreck inventories, secondary sources, and historic map analysis. Materials from archives at the Massachusetts Board of Underwater Archaeological Resources (MBUAR) were accessed. These data assisted in validating the geophysical data and interpretations. Field investigations included a marine high-resolution geophysical survey utilizing magnetometer, side scan sonar, sub-bottom profiler, and a multibeam unit. Bottom grabs and vibracores were also collected.
Documentary and field research results show the Offshore Export Cable Corridor has limited potential for human activity over time with sea level rise.9 During the pre-contact era, the entire region was subaerial only during the Paleoindian Period (approximately 12,000 years
9 Note this is historical sea level rise over thousands of years, not recent sea level rise.
4771.03/Vineyard Wind Connector 4-33 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. ago). Marine transgression rapidly covered the land during the Archaic Period and by the dawn of the Woodland Period (between approximately 500 BC and 1100 AD) only a small portion of the area would have been habitable.
Offshore surveys in 2018 extended seafloor and subsurface coverage in all areas where bottom disturbance could occur during construction activities. Survey line spacing, coverage, geophysical system parameters, and methodologies were discussed with the Massachusetts Ocean Team and complied with BOEM geophysical and geotechnical as well as archaeological guidelines applicable to this Project. The Company’s marine archaeology consultant, Gray & Pape, is still in the process of acquiring data collected during the Project’s 2018 marine geophysical and geotechnical surveys. The analysis is ongoing, and when a draft archaeological report for marine aspects of the Project is complete, it will be submitted to MHC for review and comment.
Avoidance, minimization, and mitigation measures for terrestrial and submarine historical and archaeological resources within the Project area will be determined in consultation with MHC and MBUAR through the Section 106 process.
4.10 Community Character
Since the proposed duct bank and onshore export cables will be installed entirely underground, the Project will have no permanent effect on existing land uses and will not alter the character of the land through which it will pass. Any impacts along the export cable corridor will be limited to temporary construction-period restrictions and will be mitigated with appropriate construction-period controls such as TMPs. The Project’s onshore export cable route will consist of buried concrete duct bank beneath existing roadways and will not have any permanent impact on ground-level conditions.
Development of the Project’s substation is proposed to occur within an area mapped as an Industrial and Service Trade Area on the CCC’s Land Use Vision Map; the proposed substation use is consistent with the industrial designation of the area (see Figure 4-12). As described in Section 2.4.1, the portion of the parcel that will be leased for the substation is bordered to the north by the Barnstable Switching Station, to the west by the former Cape Cod Times building, to the south by Independence Drive, and to the east by an existing approximately 150- to 200-foot-wide electric transmission corridor with a number of 115 kV overhead lines on H-frame and single pole support structures. Therefore, the proposed substation is consistent with existing land uses.
The Project is expected to generate numerous economic benefits across Massachusetts and the entire New England region (see Section 2.5). Economic benefits from the Project will be realized throughout the preconstruction, construction, operations and maintenance, and decommissioning phases. Other than the proposed substation, all proposed transmission
4771.03/Vineyard Wind Connector 4-34 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. infrastructure will be entirely underground. The offshore export cable systems in state waters and the onshore export cables installed between the Landfall Site and the substation site will have no permanent visual impacts.
The substation design includes at least a 50-foot-wide vegetated buffer on the south side of the site and at least a 30-foot-wide vegetated buffer along the east side of the site where such a buffer would not conflict with the existing utility ROW. Properties to the east are also separated from the site of the proposed substation by an existing utility ROW that leads to Barnstable Switching Station. The Project’s substation will be in an industrial/commercial area, with the existing 115 kV Barnstable Switching Station located immediately to the north, the former Cape Cod Times printing plant located immediately to the west, and an existing electric transmission corridor immediately to the east. Thus, it is consistent with existing adjacent land uses.
Noise barriers at the substation will minimize noise-related impacts at the adjacent Village Green apartment complex. The exact design of the noise barriers will continue to be refined. The anticipated noise barriers will also provide complete visual screening of the substation from locations to the east and north. Visual renderings of the substation are provided in Figure 2-10 in Section 2.
Finally, the Proponent has committed to repaving the Covell’s Beach parking lot and building a new bathhouse per the terms of the HCA.
4771.03/Vineyard Wind Connector 4-35 Resource Area Impacts and Mitigation DRI Application Narrative Epsilon Associates, Inc. Section 5.0
Consistency with Regional Policy Plan
5.0 CONSISTENCY WITH REGIONAL POLICY PLAN
This section describes the Project’s consistency with the CCC’s Regional Policy Plan (RPP). The most recent version of the RPP became effective on January 16, 2009 and was amended on August 17, 2012. The CCC is currently in the process of developing a new RPP which is expected to be approved in early 2019.
5.1 Land Use
The Land Use section of the RPP addresses patterns of growth on the Cape by, in part, emphasizing the importance of compact growth, reinforcing existing development patterns and streetscapes, and preserving open space. Project consistency with the MPS related to land use is addressed below.
5.1.1 Goal LU1 – Compact Growth and Resource Protection
Goal LU1 is “[t]o minimize adverse impacts of development on the land by using land efficiently and protecting sensitive resources, and to create vibrant communities by directing growth and redevelopment to appropriate locations.” Project consistency with the applicable Minimum Performance Standard (MPS) relevant to this goal is addressed below.
LU1.1 – Development Location
Development and redevelopment shall be consistent with the category of desired land use where the project is located as well as the characteristics of that category, both as identified on the Regional Land Use Vision Map. Notwithstanding this requirement, the Commission may find that development and redevelopment has met this requirement, if, in its discretion, it finds each of the following:
1) The proposed project is a redevelopment, or the expansion of a previously approved DRI; and,
2) The Commission finds that the proposed development does not present a threat to the resources and/or characteristics intended to be protected and maintained by its land use category.
This standard does not apply until the town has an endorsed Land Use Vision Map nor shall it apply to developments that are not designated on the Regional Land Use Vision Map.
The Town of Barnstable does not have a Land Use Vision Map; therefore, this provision does not apply.
4771.03/Vineyard Wind Connector 5-1 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. LU1.2 – Compact Development
Nonresidential development and redevelopment shall be clustered on the site and with adjacent uses to the maximum extent possible by incorporating features, as applicable, such as multistory buildings, mixed use development, minimal setbacks from the street, limited and/or shared parking, and a pedestrian-friendly design that encourages walking, biking, and transit. All residential subdivisions of five or more lots and all commercial subdivisions of land shall cluster the proposed development unless inconsistent with local bylaws. Cluster plans shall use site designs that maximize contiguous open space, respect the natural topography and character of the site, and employ shared wastewater treatment, community water supply alternatives and Low Impact Development (LID) landscaping to allow more compact development.
This Project is not a subdivision, nor is it a cluster plan or mixed use development; therefore, this MPS is not applicable to the Project.
5.1.2 Goal LU2 – Capital Facilities and Infrastructure
Goal LU2 is “[t]o use capital facilities and infrastructure efficiently and in a manner that is consistent with Cape Cod’s environment, character, and economic strengths, and that reinforces traditional village-centered development patterns.” Project consistency with the applicable MPS relevant to this goal is addressed below.
LU2.1 – Connections to Existing Infrastructure
Proposed or expanded infrastructure shall support compact development patterns, and in towns with a Land Use Vision Map, shall support the land use categories and characteristics of designated Economic Centers, Industrial and Service Trade Areas, and Villages that have been designated on the Regional Land Use Vision Map.
The Project will not change development patterns or affect land use categories; rather, the Project is intended to deliver up to 800 MW of locally-sourced, renewable energy into New England’s electrical grid. The only above-ground component of the Project on Cape Cod is the proposed substation, which is located immediately south of the existing Barnstable Switching Station on land mapped as an Industrial and Service Trade Area on the CCC Land Use Vision Map. The underground duct bank, which is proposed primarily through existing roadways and other existing rights of way (ROWs), will be entirely underground and will not affect the land use or characteristics of adjacent areas.
4771.03/Vineyard Wind Connector 5-2 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. LU2.2 – Co-location of Telecommunication Facilities
New wireless telecommunications facilities shall be required to…
The Project does not involve new wireless telecommunications facilities; therefore, this MPS does not apply.
5.1.3 Goal LU3 – Rural Lands
Goal LU3 is “[t]o preserve and enhance rural land uses, including agriculture, that are environmentally compatible with the Cape’s natural resources in order to maintain opportunities to enjoy the traditional occupations, economic diversity, and scenic resources associated with rural lands, and to support activities that achieve greater food independence for Cape Cod.”
The MPS applicable to the Rural Lands goal of the RPP pertain to agricultural lands and uses. The Project will not affect any agricultural lands or uses, and therefore this goal is not applicable to the proposed Project.
5.2 Economic Development
The Economic Development section of the RPP addresses the effort to promote economic growth while maintaining the characteristics of the Cape’s natural and human environments. Project consistency with the applicable goals and MPS related to economic development is addressed below.
5.2.1 Goal ED1 – Low-impact and Compatible Development
Goal ED1 is ”[t]o promote the design and location of development and redevelopment to preserve the Cape’s environment and cultural heritage, use infrastructure efficiently, minimize adverse impacts, and enhance the quality of life for Cape Codders.” Project consistency with the applicable MPS relevant to this goal is addressed below.
ED1.1 – Location in Economic Centers
Development shall be located in Economic Centers or Industrial and Service Trade Areas, or where appropriate, Villages as designated on the Regional Land Use Vision Map unless waived in accordance with ED1.3. For towns without a Land Use Vision Map or developments not designated on the Regional Land Use Vision Map, all DRIs shall meet the waiver requirements under ED1.3. This standard does not apply to residential subdivisions or wireless communication towers.
The underground duct bank and associated onshore export cables will not affect or alter land uses or development patterns. Development of the Project’s substation is proposed to occur within an area mapped as an Industrial and Service Trade Area on the CCC’s Land
4771.03/Vineyard Wind Connector 5-3 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. Use Vision Map, and is consistent with that designation. The proposed substation is also proposed on a site located immediately south of the existing Barnstable Switching Station, and hence is consistent with existing land use.
ED1.2 – Industrial and Service Trade Areas
Industrial and Service Trade Areas shall be reserved for light industry, warehousing, business-to-business wholesale, research and development facilities, and other uses related to the development, production, and/or distribution of goods. For towns without a Land Use Vision Map or developments not designated on the Regional Land Use Vision Map, all DRIs shall meet the waiver requirements under ED1.3.
The proposed substation site is located within an Industrial and Service Trade Area mapped on the Regional Land Use Vision Map, and is consistent with that designation. The proposed substation is also proposed on a site located immediately south of the existing Barnstable Switching Station, and hence is consistent with existing land use.
ED1.3 – Waiver
The Commission may waive ED1.1 and/or ED1.2 if the applicant demonstrates that new development meets four of the following criteria or that redevelopment meets two of the following criteria:
♦ Mixed Use: The project is a mixed-use building or development.
♦ Variety: The project includes units (two or more) designed and sized (less than 3,000 square feet) to accommodate small businesses (10 or fewer employees).
♦ Preservation: The project rehabilitates or re-uses and maintains an historic structure in accordance with federal standards for treatment of historic properties.
♦ Green Design: The project is, at a minimum, LEED/New Construction-certified at the base level.
♦ Shared Infrastructure: The project is tied into existing infrastructure, such as wastewater treatment, telecommunications, and on-site energy-generation facilities, with excess capacity and where possible allows proximate development to do the same.
♦ Emerging Industry Clusters: The project is designed to and will accommodate a business or businesses within the region’s Emerging Industry Clusters, which include marine sciences and technology; arts and culture; information and related technology; renewable and clean energy, and education and knowledge-based industries or other high-skill, high-wage, knowledge-based business activity.
4771.03/Vineyard Wind Connector 5-4 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. ♦ Un-development: The project contributes to the reduction of sprawl development, in equal proportion to the proposed development, through the purchase of land, development rights, or other methods approved by the Commission. Un- development achieved to meet this criterion must be in addition to any un- development or open space contributions made in order to meet other Minimum Performance Standards.
♦ Distributed Energy Generation: The project generates, using renewable sources, at least 25 percent of the electrical demand required by the development on site.
♦ Municipal Endorsement: The location of the project outside of a designated Economic Center, Industrial and Service Trade Area, or Village as identified on the Regional Land Use Vision Map is endorsed through a resolution from the selectmen or town council of the town(s) in which the project is located. The resolution should state that the proposed location is consistent with both the goals of the town’s Local Comprehensive Plan as well as the town’s capital facilities and infrastructure planning or plan.
As described above, the Project complies with ED1.1 and ED1.2; therefore, this MPS is not applicable.
ED1.4 – Resource-based Economic Areas
Development shall not eliminate or significantly impair the current and future function of working agricultural land, working waterfronts and harbors, fin- and shellfishing grounds, and recreational areas.
The Project will not eliminate or significantly impair current or future functions of agricultural land or recreational areas. Once installed, the offshore export cables will not affect navigation, including navigation directly over the area where the cables are installed.
Across the Offshore Export Cable Corridor, the planned burial depth of the cables is sufficient to allow continued use of mobile fishing gear, and anchors from vessels operating at the water depths in the cable area would not penetrate to the planned burial depth even in storm situations.
Please refer to Section 4.5.3 for additional discussion of fin- and shellfishing.
5.2.2 Goal ED2 – A Balanced Economy
Goal ED2 is “[t]o promote a balanced regional economy with a broad business, industry, employment, cultural, and demographic mix capable of supporting year-round and quality employment opportunities.” Project consistency with the applicable MPS related to this goal is addressed below.
4771.03/Vineyard Wind Connector 5-5 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. ED2.1 – Gaming
Development shall not involve Class III gaming given the stresses it places on the region’s environment, transportation infrastructure, and economy.
The proposed Project does not involve gaming, and therefore this MPS is not applicable.
5.2.3 Goal ED3 – Regional Income Growth
Goal ED3 is “[t]o promote economic activity that retains and attracts income to the region and benefits residents, thus increasing economic opportunity for all.” Although there are no MPS associated with this goal, the RPP does identify some best management practices recommended to promote this goal. The best management practices that could potentially be applicable to the Project are addressed below. Best management practices not applicable to the Project are not addressed below, including: ED3.2, local ownership; ED3.4, regional export growth; ED3.5, regional import substitution; and ED3.6, value- added manufacturing.
ED3.1 – Local Labor and Service Providers
Commercial DRIs are encouraged to employ a majority of local residents and use a majority of local contractors, suppliers, professional service providers, and products during the planning, construction, and operational phases of the project.
The proposed Project is not a commercial DRI, and therefore this MPS is not applicable.
The Project does provide substantial economic opportunity to the region and its residents. Economic benefits from the project are is provided in Section 2.5.
ED3.3 – Diverse Employment Opportunities
Commercial DRIs are encouraged to employ or directly benefit residents with disabilities, minorities, elderly, unemployed, and under-employed residents, and/or hires minority- and women-owned contractors.
Given that offshore wind is a new industry to the United States, all direct employment in this industry will be developed as the construction and operations are finalized and benefits will be accessible to all residents of Southeastern Massachusetts, including some of the state’s most traditionally disenfranchised communities.
In cooperation with the MA Clean Energy Center, Vineyard Wind committed prioritizing hiring locally whenever possible. As part of its Windward Workforce initiative, Vineyard Wind is working with the Massachusetts Clean Energy Center to partner with educational and workforce institutions throughout the state to develop and implement training programs that will allow local residents of all backgrounds to enter into the offshore wind workforce.
4771.03/Vineyard Wind Connector 5-6 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. One requirement of workforce training proposals solicited by Mass CEC in November 2018 is the outreach to and inclusion of women and minorities into these training programs. Vineyard Wind expects to use its $2 million Windward Workforce fund to enhance these efforts, working closely with area vocational schools and community colleges.
Additional benefits to Cape residents will be implemented through Vineyard Wind’s $15 million Resilience and Affordability Fund. This fund will assist host communities on the Cape and Islands through low-income rate relief, efficiency projects with a priority on low- income and senior residences, and implementing pilot programs and technologies to boost energy resiliency at places on the grid that are most vulnerable. Recent years have demonstrated that the Cape’s most vulnerable populations (low income and elderly) are most at risk with storms and power outages. This program will help to enhance energy reliability and affordability where it is needed most, providing much needed energy security to the Cape’s most vulnerable residents.
ED3.7 – Local Fiscal Impact
Commercial DRIs are encouraged to have a positive net fiscal impact on the community in which it is located.
The proposed Project is not a commercial DRI, and therefore this MPS is not applicable.
However, as described in relation to public benefits in Section 2.5, the Project is expected to generate numerous economic benefits across Massachusetts and the entire New England region.
5.2.4 Goal ED4 – Infrastructure Capacity
Goal ED4 is “to provide adequate capital facilities and infrastructure that meet community and regional needs, expand community access to services, and improve the reliability and quality of services.” Project consistency with the applicable MPS related to this goal is addressed below.
ED4.1 – Demonstrated Need and Public Benefit
Development of infrastructure and/or capital facilities shall be in response to existing regional demand and shall improve the availability, reliability, quality, and cost of services.
The purpose of the Vineyard Wind Project is to provide a commercially sustainable wind energy project within its leased area to meet New England’s need for clean energy. The Vineyard Wind lease area is located in federal waters off Massachusetts, and is part of the federally-designated Wind Energy Area on the Outer Continental Shelf. The Project will deliver up to 800 MW of power to the New England energy grid, and will help meet individual state renewable energy requirements. The Project adds high and stable winter capacity factor offshore wind generation to the region, increasing resources available to
4771.03/Vineyard Wind Connector 5-7 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. address electricity demand spikes, and reducing reliance on fossil fuel generation. The Project will therefore be unaffected by the risk of potential fossil fuel shortages and will help to alleviate price volatility. The Project could reduce the need for the gas- and oil-burning Canal units 1 and 2 to run, especially during winter peak events when winds are high and conditions ideal for wind energy generation.
As the first commercial-scale offshore wind project in the United States, Vineyard Wind is a crucial part of anchoring this burgeoning clean energy industry in southeastern Massachusetts, which will have substantial long-term economic benefits for Cape Cod and other parts of southern New England
As described in Section 2.5, the Project will also provide a number of benefits to the reliability and cost of electric power in Barnstable County and elsewhere in Massachusetts
5.3 Water Resources
The Natural Systems section of the RPP contains the goals and policies applicable to water resources on the Cape. Consistency with the applicable goals and MPS related to water resources is addressed below.
5.3.1 Goal WR1 – General Aquifer Protection
Goal WR1 is “[t]o maintain the hydrogeologic balance and quality of Cape Cod’s aquifer, considering such factors as groundwater withdrawals, wastewater disposal, stormwater recharge, and adequate surface water levels.” Project consistency with the applicable MPS related to this goal is addressed below.
WR1.1 – Five-ppm Nitrogen Loading Standard
All development and redevelopment shall not exceed a 5-parts-per-million (ppm) nitrogen loading standard for impact on groundwater unless an alternative standard applies in accordance with the water resources classification system as described in the Water Resources planning section found on page 27. Guidance on methodology to meet this standard can be found in Cape Cod Commission Nitrogen Loading Technical Bulletin 91- 001, as amended.
The Project will not contribute to nitrogen loading, and therefore this MPS is not applicable. A Stormwater Management Report for the proposed substation is provided in Attachment H.
WR1.2 – Identification of Drinking Water Wells
Development and redevelopment shall identify their proposed drinking water wells and existing private drinking water wells on abutting properties within 400 feet and assess the impact of the development on the water quality of these wells and all other existing wells
4771.03/Vineyard Wind Connector 5-8 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. that may potentially be affected by the proposed development. Septic systems and other sources of contamination shall be sited to avoid adversely affecting downgradient existing or proposed wells.
The Project will not require the installation of any drinking water wells or septic systems. The Health Department in Barnstable does not keep records of private well locations. It is worth noting, however, that Town water service is present in all roadways along the Covell’s Beach route, and therefore it is most likely that parcels are supplied by that Town infrastructure and not private wells. Regardless, the onshore export cables will have no effect on wells. The Project is predominantly located along roadways and involves standard inert materials such as concrete, PVC conduit, and solid dielectric cable. The proposed cables will not contain any liquids, oils, or other substances that could leak out of the cables.
Please see Section 4.2 for a discussion of groundwater protection.
WR1.3 – Groundwater Study Requirement
Developments of Regional Impact that withdraw more than 20,000 gallons of water per day shall…
The Project will have no groundwater withdrawals; therefore, this MPS does not apply.
WR1.4 – Cluster Development
All residential subdivisions of five or more lots and all commercial subdivisions of land shall cluster the proposed development unless inconsistent with local bylaws…
The Project does not involve a subdivision development; therefore, this MPS does not apply.
WR1.5 – Turf and Landscape Management
Development and redevelopment shall adopt Best Management Practices such as a turf and landscape management plan that incorporates water conservation measures including the use of native and drought resistant plantings and the use of drip irrigation, and minimizes the amount of pesticides and chemical fertilizers.
Vegetation control will not be necessary along the duct bank route, and hence no use of fertilizers, pesticides, or herbicides will be necessary. The substation design does include at least a 50-foot-wide vegetated buffer on the south side of the site and, in areas where it will not interfere with the existing utility ROW, at least a 30-foot-wide vegetated buffer along the east side of the site. The Proponent does not anticipate landscaping these areas, but rather leaving a naturally-vegetated buffer; therefore, no irrigation or application of fertilizers, pesticides, or herbicides is anticipated.
4771.03/Vineyard Wind Connector 5-9 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. 5.3.2 Goal WR2 – Drinking Water Quality and Quantity
Goal WR2 is “[t]o maintain the overall quality and quantity of Cape Cod’s groundwater to ensure a sustainable supply of untreated high-quality drinking water.”
The MPS associated with this goal apply to development within Wellhead Protection and Potential Water Supply Areas. The proposed substation is located within a Wellhead Protection Area and thus Vineyard Wind has designed the substation to ensure that the presence and use of dielectric fluid at the substation does not present a threat to groundwater. Please refer to Section 4.2.2.
WR2.1 – Five-ppm Nitrogen Loading Standard
The maximum nitrogen loading standard for impact on groundwater shall be 5 ppm for development and redevelopment unless a cumulative impact analysis indicates a more stringent loading standard is necessary.
The Project will not generate any nitrogen that could potentially affect nitrogen loading of water systems on the Cape.
WR2.2 – Prohibition on Hazardous Materials/Wastes
Development and redevelopment that involves the use, treatment, generation, handling, storage, or disposal of Hazardous Materials or Hazardous Wastes, with the exception of household quantities, shall not be permitted in Wellhead Protection Areas, except as provided in WM1.2 and WM1.3.
Other than during construction (discussed in 4.2.3.4), and the substation (discussed in 4.2.2), the Project will not involve the use, treatment, generation, handling, storage, or disposal of Hazardous Materials or Hazardous Wastes in Wellhead Protection Areas. The Project is predominantly located along roadways and involves standard inert materials such as concrete, PVC conduit, and solid dielectric cable. The proposed cables will not contain any liquids, oils, or other substances that could leak out of the cables.
Construction activities meet the requirements of WM1.2, in that techniques will be used to avoid adversely affecting water quality in the Wellhead Protection Areas. As identified in Section 4.2.3.2, limitations will be placed on the location and nature of machinery fueling to preclude impacts to water quality, equipment will be inspected for incidental leaks, and no fuel or oils of any kind be stored or brought into any duct bank vault
Similarly, the substation meets the requirements of WM 1.2. The proposed substation will include an integrated fluid containment system capable of capturing the full volume (110%) of dielectric fluid from all substation components plus an additional volume to account for a simultaneous 100-year, 24-hour rainfall event (please see Section 4.2.2).
4771.03/Vineyard Wind Connector 5-10 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. WR2.3 – Restrictions on Public and Private Wastewater Treatment Facilities
Public and private wastewater treatment facilities with Title 5 design flows greater than 10,000 gallons per day shall not be permitted in Wellhead Protection Areas…
The Project is not a wastewater treatment facility nor does it have Title 5 design flows greater than 10,000 gallons per dy; therefore, this MPS does not apply.
WR2.4 – Prohibited Uses under State Regulations
Uses prohibited in Zone IIs by state regulations shall not be permitted.
The Project is not a prohibited use in Zone II under the state regulations.
WR2.5 – Future Well Site Restrictions
No development shall be permitted within 400 feet of an identified future well site.
To the Proponent’s knowledge and following consultation with the Town of Barnstable, the Project is not located within 400 feet of an identified future well site.
WR2.6 – One-ppm Nitrogen Loading Standard
The maximum nitrogen loading standard for impact on groundwater shall be 1 ppm for development. Guidance on methodology to meet this standard can be found in Cape Cod Commission Nitrogen Loading Technical Bulletin 91-001, as amended.
Onshore duct bank and the proposed substation will not contribute to nitrogen loading. Onshore duct bank construction will not involve the discharge of wastewater, and it will not create any new sources of stormwater runoff (i.e., new impervious area will not be created along the duct bank route). The proposed substation in Barnstable will not involve discharge of wastewater, and a Stormwater Management Plan has been developed which demonstrates that the substation site will comply with the Massachusetts Stormwater Policy and employ low-impact development (LID) strategies to minimize stormwater runoff and treat any runoff generated from paved areas (i.e., access way and parking) prior to recharge to the ground (see Attachment H).
The nitrogen loading model presented in the CCC’s Nitrogen Loading Technical Bulletin 91-001 was used to evaluate potential nitrogen loading from the substation site (see Attachment H). Since fertilizer use is not proposed for this site, the projected nitrogen loading will be less than the 1 ppm standard noted above.
4771.03/Vineyard Wind Connector 5-11 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. 5.3.3 Goal WR3 – Marine Water Embayments and Estuaries
Goal WR3 is “[t]o preserve and restore the ecological integrity of marine water embayments and estuaries.” As shown on Figure 5-1, the Project is located within Marine Water Recharge Areas as identified on the RPP’s Cape Cod Water Resources Classification Map II.
WR3.1 – Critical Nitrogen Load Standard for Development
In watersheds to estuaries/embayments where a critical nitrogen load has been determined, through either a Total Maximum Daily Load (TMDL), or a Massachusetts Estuaries Project- accepted technical report, development and redevelopment shall not exceed the identified critical nitrogen loading standard for impact on marine ecosystems, except as provided in WR3.3. The Commission shall maintain a list and map of estuary/embayment critical nitrogen loading standards that shall be the basis for applying this MPS; the list and map will be updated on a regular basis as TMDLs are approved by the Massachusetts Department of Environmental Protection and the US Environmental Protection Agency.
The Project will not contribute to nitrogen loading. Please see the response to MPS WR2.6.
WR3.2 – Maintenance or Improvement of Nitrogen Loading
In watersheds to estuaries/embayments where there are documented marine water quality problems and a critical nitrogen load has not been developed, including but not limited to those embayments shown on the Cape Cod Water Resources Classification Map, development and redevelopment shall maintain or improve existing levels of nitrogen loading, except as provided in WR3.3 and WR3.1.
The Project meets WR2 because it will not alter or contribute to existing levels of nitrogen loading.
WR3.3 – Local Management Plans
In lieu of the requirements set forth in MPS 3.1 and 3.2, in watersheds with Commission- approved watershed nutrient management plans, or Commission-approved comprehensive wastewater management plans, nitrogen loading from development and redevelopment shall attain the nitrogen loading limit specified by the plan.
The Project will not contribute to nitrogen loading. Please see the response to MPS WR2.6.
WR3.4 – Nitrogen Offset Contribution
In watersheds to estuaries/embayments where development and redevelopment must meet either WR3.1 or WR3.2, development and redevelopment may meet these standards by providing an equivalent nitrogen offset contribution to be used toward meeting the intent of WR3.1 or WR3.2 as provided in the following paragraph.
4771.03/Vineyard Wind Connector 5-12 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The load requirements of WR3.1 and WR3.2 above may be achieved by providing wastewater treatment for the development or redevelopment and additional treatment capacity for nearby land uses, installation of alternative denitrifying technologies for existing septic systems in the same Marine Water Recharge Area, and/or an equivalent contribution of $1,550 per kg/yr of nitrogen towards a municipal or watershed effort that achieves the intent of WR3.1 and WR3.2.
The Project will not contribute to nitrogen loading, and there will be no need to provide an equivalent nitrogen offset contribution to comply with policies WR3.1 or WR3.2.
WR3.5 – Monetary Contribution
In watersheds where the critical nitrogen load has not been determined, development and redevelopment may be required to make a monetary contribution toward the development or implementation of appropriate nitrogen management strategies not to exceed $20 per gallon of design flow of wastewater per day.
The Project does not involve wastewater flows and will not contribute to nitrogen loading; therefore, this MPS is not applicable.
WR3.6 – Public and Private Wastewater Treatment Facilities
Public and private wastewater treatment facilities may be used within Marine Water Recharge Areas subject to MPS WR5.2 and MPS WR6.1 through MPS WR6.9 below.
The Project is not a wastewater treatment facility; therefore, this MPS does not apply.
5.3.4 Goal WR4 – Freshwater Ponds and Lakes
Goal WR4 is “[t]o preserve and restore the ecological integrity of freshwater ponds and lakes.” The associated MPS apply to Freshwater Recharge Areas as shown on the CCC’s Water Resources Classification Map I. As shown on Figure 5-2, the southernmost end of the proposed substation site is just within a mapped Freshwater Recharge area.
WR4.1 – Limits on Subsurface Disposal Systems
In order to limit phosphorus inputs, no subsurface wastewater disposal systems shall be permitted within 300 feet of maximum high water of freshwater ponds…
The Project does not involve a subsurface wastewater disposal system; therefore, this MPS does not apply.
4771.03/Vineyard Wind Connector 5-13 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. WR4.2 – Monetary Contribution
If a fresh water pond has documented water quality problems, DRIs located in the pond’s watershed shall be required to make a monetary contribution toward the development or implementation of appropriate water quality assessment work or management strategies.
The Proponent is not aware of fresh water ponds with documented water quality problems within the project watershed.
WR4.3 – Public and Private Wastewater Treatment Facilities
Public and private wastewater treatment facilities may be used within Freshwater Recharge Areas subject to Goal WR6 and MPS WR6.1 through MPS WR6.9 below.
The Project does not involve a public or private wastewater treatment facility; therefore, this MPS does not apply.
5.3.5 Goal WR5 – Water Quality Improvement Areas
Goal WR5 is “[t]o improve impaired water quality in Wellhead Protection, Marine Water Recharge, and Freshwater Recharge Areas.” The associated MPS apply to development within Water Quality Improvement Areas. These Water Quality Improvement Areas are Impaired Areas on the CCC’s Water Resources Classification Map I that are also located in any of the following: Wellhead Protection Areas, Freshwater Recharge Areas, or Marine Water Recharge Areas. Figure 5-3 illustrates the proposed route relative to Water Quality Improvement Areas mapped in accordance with this definition from the RPP. Portions of the proposed route pass through Water Quality Improvement Areas, and the western side of the proposed substation site is also located within one of these mapped areas. Project consistency with the applicable MPS related to this goal is addressed below.
WR5.1 – Nitrogen Loading Standard
Development and redevelopment shall not exceed the nitrogen loading standards for Wellhead Protection Areas or an identified marine water quality standard as applicable. Where existing development within the watershed exceeds the identified loading standard or where there are documented marine water quality problems, nitrogen loading from development and redevelopment shall be maintained or improved.
The Project will not contribute to nitrogen loading. Please see the response to MPS WR2.6.
WR5.2 – Public and Private Wastewater Treatment Facilities
Use of public and private wastewater treatment facilities shall be as follows…
4771.03/Vineyard Wind Connector 5-14 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The Project does not involve a public or private wastewater treatment facility; therefore, this MPS does not apply.
WR5.3 – Monetary Contribution in Designated Mapped Areas
Development and redevelopment in designated Economic Centers, Industrial and Service Trade Areas, Villages, and Growth Incentive Zones within Water Quality Improvement Areas that have been identified as requiring comprehensive wastewater treatment solutions shall, in the Commission’s discretion, be required to provide a monetary contribution, not to exceed $20 per gallon of design flow of wastewater per day, towards community wastewater facility planning or implementation efforts that may include infrastructure for wastewater management, if in the Commission’s judgment, such contribution would assist in the planning or implementation of such infrastructure. In towns without a Land Use Vision Map, this MPS shall only apply to development and redevelopment in Water Quality Improvement Areas.
As described above and shown on Figure 5-3, the proposed route passes through Water Quality Improvement Areas, and the western side of the proposed substation site is also located within one of these mapped areas. However, the Project will not generate wastewater, and will not affect wastewater treatment facilities.
WR5.4 – Nitrogen Loading Standard in Impaired Areas
For Impaired Areas outside of other mapped water resource areas, development and redevelopment shall generally meet a 5-ppm nitrogen loading standard for impact on groundwater, but the standard may be increased where it can be demonstrated to the Commission that such increase will cause no adverse impact on ponds, wetlands, marine waters, public or private drinking water supply wells, and potential water supply wells as identified under Goal WR2.
The Project will not contribute to nitrogen loading. Please see the response to MPS WR2.6.
WR5.5 – Alternative Water Supply in Designated Mapped Areas
Development in designated Economic Centers, Industrial and Service Trade Areas, Villages, or Growth Incentive Zones in areas serviced by private water supplies shall connect to public water supply, and at the Commission’s discretion, shall connect existing development to public water supply in the event that said development impacts such existing development. In towns without a Land Use Vision Map, this MPS shall apply only to Impaired Areas.
If potable water supplies are required, the Project will connect to public water supplies to the extent available.
4771.03/Vineyard Wind Connector 5-15 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. 5.3.6 Goal WR6 – Public and Private Wastewater Treatment Facilities
Goal WR6 is “[t]o encourage the use of public and private wastewater treatment facilities in appropriate areas where they will provide environmental or other public benefits and where they can be adequately managed and maintained.” The associated MPS apply to development proposing wastewater treatment facilities.
The Project does not involve a public or private wastewater treatment facility, nor does it involve discharges of wastewater; therefore, the associated MPS do not apply.
5.3.7 Goal WR7 – Stormwater Quality
Water Resources Goal WR7 is “[t]o protect the overall water quality of the aquifer and its resources by minimizing impervious surfaces and improving stormwater quality as much as possible.” Project consistency with the applicable MPS related to this goal is addressed below.
WR7.1 – No New Direct Discharges of Untreated Stormwater
New direct discharge of untreated stormwater, parking lot runoff, and/or wastewater into marine and fresh surface water and natural wetlands shall not be permitted.
Since the Project’s onshore export cable route will consist of buried concrete duct bank primarily beneath existing roadways, it will not have any permanent impact on ground-level conditions. The only permanent ground-level alteration will occur at the site of the proposed substation, where stormwater management will occur in accordance with the Stormwater Management Report provided as Attachment H and discussed in Section 4.2.2.2.
During construction, stormwater and erosion control will be managed through best management practices (BMPs) (see Section 4.2.3.3). The Proponent’s objective is to minimize the potential for erosion and sedimentation impact during Project construction, and to effectively restore any disturbed areas. In general, the measures are designed to minimize erosion and sedimentation by:
♦ Minimizing the quantity and duration of soil exposure;
♦ Protecting areas of critical concern during construction by redirecting and reducing the velocity of runoff;
♦ Installing and maintaining erosion and sediment control measures during construction;
♦ Establishing vegetation where required as soon as possible following final grading; and
4771.03/Vineyard Wind Connector 5-16 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. ♦ Inspecting the construction route and maintaining erosion and sediment controls as necessary until final stabilization is achieved and final inspections completed.
The contractor will be responsible for implementing and maintaining erosion and sediment control measures during construction. The Environmental Monitor or designee (such as a construction supervisor) will provide oversight of the contractor’s activities. Erosion and sediment control techniques will apply to all areas of upland construction.
There will be no new direct discharges of untreated stormwater as a result of the Project.
WR7.2 – On-Site Infiltration
Stormwater for all roadways and parking areas shall be managed and infiltrated on site, close to the source, to minimize runoff and maximize water quality treatment. Stormwater water quality treatment shall be provided for the first inch of rainfall (25-year 24-hour storm) consistent with 310 CMR and the Massachusetts Stormwater Management Handbook to attain 80-percent total suspended solids removal and to reduce nutrients. All designs shall provide for at least 44-percent total suspended solids removal shall be designed prior to discharge into structured infiltration systems.
The only impervious surface resulting from the Project will be the internal perimeter road and small parking area associated with the proposed substation; in total, the Project will create approximately 0.7 acres of impervious surface on the substation site. Stormwater management will occur in accordance with the Stormwater Management Report provided as Attachment H, and will comply with the Massachusetts Stormwater Policy and employ low-impact development (LID) strategies to minimize stormwater runoff and treat any runoff generated from paved areas (i.e., access way and parking) prior to recharge to the ground.
During construction, stormwater management and erosion control will consist of BMPs that will apply to all areas of upland construction. These controls will be maintained throughout construction until any disturbed surfaces have been stabilized.
WR7.3 – Roof Runoff
Roof runoff shall be managed separately and directly infiltrated unless there is an identified rooftop water quality concern that requires additional treatment or management.
The only new roof area created by the Project will be a small, approximately 1,200-square- foot control house/equipment enclosure on the substation site, and potentially an additional enclosure for the synchronous condensers. Stormwater runoff will drain onto the surrounding crushed stone yard, where it will infiltrate into the ground (existing soil types do not limit infiltration). There will be no rooftop water quality concerns that would require pretreatment of rooftop runoff prior to recharge.
4771.03/Vineyard Wind Connector 5-17 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. WR7.4 – Biofiltration Practices
Stormwater design for the first inch of stormwater flow from development parking and roadways shall use biofiltration practices including, but not limited to, vegetated swales and filter strips, constructed wetlands, tree box filters, bio-retention basins and rain gardens for treatment of stormwater runoff. Bioretention areas shall be constructed in accordance with the Massachusetts Storm Water Management Volume One: Stormwater Policy Handbook, March 1997. Approved biofiltration areas may be counted as open space within Wellhead Protection Areas.
Stormwater management on the site of the proposed substation is described in the Stormwater Management Report provided as Attachment H, and will comply with the Massachusetts Stormwater Policy and employ low-impact development (LID) strategies to minimize stormwater runoff and treat any runoff generated from paved areas (i.e., access way and parking) prior to recharge to the ground. An LID approach to stormwater management was implemented for this Project by keeping stormwater predominately confined to the site by capture and recharge as close to the point of origin as possible. The proposed grass swales, sediment forebays, deep sump catch basin, and infiltration basin will provide a treatment train to improve the quality of stormwater runoff, reduce the quantity of runoff, and provide infiltration and recharge to groundwater. MassDEP considers these methods Best Management Practices (BMPs). The infiltration basin will be planted with vegetation that is appropriate for a very well-drained rain garden setting that experiences occasional flooding. Plantings will enhance basin aesthetics and prevent erosion, and root growth will provide benefits in the form of water and nutrient uptake as well as preservation of soil permeability within the basin. This basin will receive only pretreated stormwater runoff and will not serve as a settling basin. Stormwater will be pretreated to remove at least 44% of total suspended solids (TSS) before being released to the infiltration basin in accordance with the Massachusetts Stormwater Policy, and as applicable to a site located within a Zone II water supply protection area.
WR7.5 – Structures Infiltration Devices
Structured infiltration devices shall be used to accommodate frozen flow conditions and storms that exceed the 25-year 24-hour storm and designed to be consistent with the Massachusetts Stormwater Standards under 310 CMR10 and the Massachusetts Storm Water Management Handbook.
See the response to MPS WR7.4 above. The stormwater infiltration basin will be conservatively designed to provide adequate storage capacity for larger storm events during cold weather conditions; however, it is also generally recognized that if it is warm enough to rain, then infiltration to the ground will continue to occur, especially at the bottom of a protected infiltration basin such as proposed. Snow shall be plowed, pushed, or blown to the sides of paved areas, and snow will not be stored in the infiltration basin or within the sediment forebays or deep sump catch basin area. During extremely large snow storms,
4771.03/Vineyard Wind Connector 5-18 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. snow will be collected and deposited in designated snow storage areas within the substation yard (snow storage plan to be prepared). If necessary, snow will be removed from the site.
WR7.6 – Impervious Surfaces
Roadway and parking design shall limit impervious surfaces. Parking lots shall be designed for the minimum required by the town in accordance with MPS TR2.9. Overflow peak parking design shall be constructed from pervious materials such as porous pavement, permeable pavers, or biomaterial such as grass pavers unless inconsistent with local bylaws. Bioretention shall be incorporated into parking islands and roadway perimeters. Permeable paving shall be encouraged where appropriate.
The parking area requirements of the substation are minimal, and therefore there will be no need for “overflow parking” or parking lot islands as referenced above. Porous pavement, though initially considered for the substation site, was determined to be inappropriate given that the site is in a Zone II and the access road will receive some “run on” from the crushed stone yard areas during extreme rain events. As stated in the Massachusetts Stormwater Policy Manual1, the use of permeable or porous pavement is not a recommended practice within a Zone II water supply protection area.
The Company is in discussions with Town officials about the size of containment at the substation. If additional impervous surface is created as a result the Company will take appropriate steps to allow for infiltration.
WR7.7 – Structured Infiltration Devices in Designated Mapped Areas
Structured detention basins, infiltration basins and galleries may be used for redevelopment in Impaired Areas, Economic Centers, Industrial and Service Trade Areas, Villages, and Growth Incentive Zones. In towns without a Land Use Vision Map, this MPS shall only apply to redevelopment in Impaired Areas.
The site of the proposed substation is within an Industrial and Service Trade Area as mapped by the CCC’s Land Use Vision Map. Regardless, the proposed infiltration basin will receive only pretreated stormwater runoff and will not serve as a settling basin. Stormwater will be pretreated to remove at least 44% of total suspended solids (TSS) before being released to the basin in accordance with Massachusetts Stormwater Policy, and as applicable to a site located within a Zone II water supply protection area.
1 See MassDEP Stormwater Policy Manual, Structural BMPs. Volume 2, Chapter 2, page 118.
4771.03/Vineyard Wind Connector 5-19 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. WR7.8 – Minimum Two-foot Separation to Groundwater
New infiltration basins or other stormwater leaching structures shall maintain a minimum two-foot separation between points of infiltration and maximum high water table except as required under MPS CR3.4. Guidance on the high groundwater adjustment methodology can be found in Estimation of High Groundwater Levels for Construction and Land Use Planning, Technical Bulletin 92-001, as amended.
The new infiltration basin will be designed to maintain a minimum two-foot separation between points of infiltration and maximum high water table. Although on-site soil and high groundwater conditions will be confirmed via test pits and soil evaluations by a Massachusetts-certified Soil Evaluator, soils data available from the Natural Resource Conservation Service (NRCS) indicate that depth to groundwater at the site is more than 80 inches (>6.7 feet) (Vineyard Wind investigations indicate it is even deeper). Therefore, restrictions sometimes presented by high groundwater are not expected at the substation site.
WR7.9 – Best Management Practices during Construction
Construction BMPs for erosion and sedimentation controls shall be specified on project plans to prevent erosion, control sediment movement and stabilize exposed soils.
During construction, stormwater and erosion control will be managed through best management practices (BMPs) described in the draft Construction Management Plan (CMP) provided in Attachment C of the DEIR. The Proponent’s objective is to minimize the potential for erosion and sedimentation impact during Project construction, and to effectively restore any disturbed areas. In general, the measures are designed to minimize erosion and sedimentation by:
♦ Minimizing the quantity and duration of soil exposure;
♦ Protecting areas of critical concern during construction by redirecting and reducing the velocity of runoff;
♦ Installing and maintaining erosion and sediment control measures during construction;
♦ Establishing vegetation where required as soon as possible following final grading; and
♦ Inspecting the construction route and maintaining erosion and sediment controls as necessary until final stabilization is achieved and final inspections completed.
4771.03/Vineyard Wind Connector 5-20 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The contractor will be responsible for implementing and maintaining erosion and sediment control measures during construction. The Environmental Monitor or designee (such as a construction supervisor) will provide oversight of the contractor’s activities. Erosion and sediment control techniques will apply to all areas of upland construction.
WR7.10 – Stormwater Maintenance and Operation Plan
Development and redevelopment shall submit a Professional Engineer-certified stormwater maintenance and operation plan demonstrating compliance with the Massachusetts Stormwater Guidelines including a schedule for inspection, monitoring, and maintenance. The plan shall identify the parties responsible for plan implementation, operation and maintenance. The identified responsible party shall keep documentation of the maintenance and inspection records and make these available to the Commission or local board of health upon request. One year from completion of the system, a Professional Engineer shall inspect the system and submit a letter certifying that the system was installed and functions as designed.
A Stormwater Management Report for the proposed substation site is provided as Attachment H; Section 5 of that report contains an Operations and Maintenance Plan for proposed stormwater BMPs.
WR7.11 – Shut-off Valve in Wellhead Protection Areas
In Wellhead Protection Areas, stormwater systems for land uses that have a high risk of contaminating groundwater, such as vehicle maintenance areas and loading docks, shall install a mechanical shut-off valve or other flow-arresting device between the catch basin or other stormwater-capture structure draining this area and the leaching structures.
The proposed containment system is described in Section 4.2.2.1.
5.4 Coastal Resources
The Natural Systems section of the RPP contains the goals and policies applicable to coastal resources. Project consistency with the applicable goals and MPS related to wetlands is addressed below.
5.4.1 Goal CR1 – Maritime Industry, Character, and Public Access
Goal CR1 is “[t]o protect and enhance public and traditional maritime interests and the public trust rights for fishing, fowling, and navigation, to preserve and manage coastal areas so as to safeguard and perpetuate their biological, economic, historic, maritime, and aesthetic values, and to preserve, enhance, and where appropriate, expand public access to the shoreline.” Project consistency with the applicable MPS is discussed below.
4771.03/Vineyard Wind Connector 5-21 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. CR1.1 – Public Access
Development and redevelopment along the coast shall not interfere with existing legal public access and historic public rights of way to the shore. In addition, public access shall not impair the natural beneficial functions of coastal resources.
The Project will have no permanent ground-level impacts along the coast, and hence will have no adverse effect on public access or public rights of way to the shore. As a commitment in the Host Community Agreement (see Attachment C) , Vineyard Wind will enhance public access to the shore by providing funding for a new bathhouse at Covell’s Beach.
Furthermore, Project installation will occur outside of the busy summer recreational season, and access to portions of the Covell’s Beach parking area and the beach itself will be available even during construction. Therefore construction activities will also avoid impacts to public shore access.
CR1.2 – Public Access to Beach Nourishment Sites
Public access shall be provided for all publicly funded beach-nourishment sites where such access will not significantly impair natural resources.
The Project does not involve beach nourishment; therefore, this MPS does not apply.
CR1.3 – Maritime Industry
Existing water-dependent facilities within 250 feet of the mean high water line or shoreward of the first public way, whichever is less, shall not be changed to a non-water-dependent use unless an overriding public benefit is provided to accommodate for the loss of the water-dependent use…
The Project does not involve changing a water-dependent facility to a non-water-dependent facility; therefore, this MPS does not apply.
CR1.4 – Maritime Aesthetics
Development and redevelopment shall reflect the traditional maritime character and/or architecture typical of the area and shall be designed to maintain and enhance views of the ocean and/or shoreline from public ways, waterways, access points, and existing development.
4771.03/Vineyard Wind Connector 5-22 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. Along the south coast of Cape Cod, the Project consists of buried offshore export cables and underground duct bank/onshore export cables, and thus will not have any permanent impact on ground-level conditions along the coast. The Project will not change existing views of the ocean or shoreline from the south coast of Cape Cod, and will not affect public access.
5.4.2 Goal CR2 – Coastal Hazard Mitigation
Goal CR2 is “[t]o limit development in the coastal zone, particularly high-hazard areas, in order to protect the natural beneficial functions of coastal resources so that they serve to prevent or minimize human suffering and loss of life and property or environmental damage resulting from storms, flooding, erosion, and relative sea-level rise.” Project consistency with the applicable MPS is discussed below.
CR2.1 – Prohibiting Development in V-Zones
No development or redevelopment shall be permitted within V-Zones, except as specified in MPS CR2.7. Existing structures may be reconstructed or renovated provided there is no increase in gross floor area, footprint, or intensity of use (including but not limited to increases in wastewater flow, impervious area, or parking spaces, or conversion from seasonal to year-round use). As an exception, where there is no feasible alternative, water- dependent structures and uses and maintenance of marine infrastructure may be permitted provided the activity minimizes impacts to coastal resources and is subject to the approval of all permitting authorities.
The Vineyard Wind Connector is presumptively water-dependent: the Massachusetts regulations at 310 CMR 9.12(2)(e), provide that “in the case of a facility generating electricity from wind power (wind turbine facility) or any ancillary facility therefore, for which an EIR is submitted, the Department shall presume such facility to be water dependent if the Secretary has determined that such facility requires direct access to or location in tidal waters.”
As a transmission project designed to connect infrastructure in an offshore Wind Development Area located in federal waters to an interconnection point on shore that is part of the regional electric grid, the Vineyard Wind Connector must necessarily cross flowed tidelands and cannot be located away from those tidelands while achieving the expressed Project purpose.
Figure 4-4 in Section 4 illustrates the MassGIS flood zones as defined by the Federal Emergency Management Agency (FEMA) 100-year storm elevations along the Covell’s Beach route. The Covell’s Beach Landfall Site is within Zone VE, which FEMA defines as an area with a 1% annual chance of being flooded with additional hazards due to storm- induced velocity wave action. The proposed work will not permanently alter the existing landscape nor otherwise alter or exacerbate existing coastal storm flooding conditions. In
4771.03/Vineyard Wind Connector 5-23 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. addition, MPS 2.10 (General Exceptions) exempts certain activities from the V-zone standard in MPS CR2.1, including “underground utility crossings that do not disturb protected resources” if BMPs are used to minimize adverse impacts and where all other MPS for underlying resource areas are met. As described, the Project includes BMPs to protect coastal resources.
CR2.2 – Accommodating Relative Sea-level Rise
All new buildings, including replacements, or substantial improvements to existing structures shall be designed as follows to accommodate documented relative sea-level rise rates in Massachusetts:
1) Within A-Zones, the lowest horizontal structural member shall be a minimum of one foot above Base Flood Elevation (BFE); or
2) Within V-Zones, due to wave action, the lowest horizontal structural member shall be a minimum of two feet above BFE
The Project does not involve any buildings within A-zones or V-zones; therefore, this MPS does not apply.
CR2.3 – Migration of Coastal Resources
New development and redevelopment within the 10-year floodplain shall not impede the landward migration of resources, such as salt marshes, coastal dunes, coastal beaches, tidal flats, or coastal floodplain. The landward migration of coastal resources in response to relative sea-level rise shall be incorporated into the location, design, and construction of structures and other activities proposed.
To ensure that the proposed onshore infrastructure will not be vulnerable to shoreline erosion, the Proponent performed a shoreline change analysis. Shoreline change at the Covell’s Beach Landfall Site is shown on Figure 4-7, which illustrates that since 1846 the shoreline has accreted approximately 150 feet. The HDD pit and transition vault would be located well back from the existing high waterline (see Figure 4-8). Based on this analysis, proposed infrastructure associated with the Landfall Site would be sufficiently set back from the shoreline. Furthermore, the Project’s buried ductbank and export cables will comply with performance standards of the Massachusetts Wetlands Protection Act, and construction techniques will ensure the Project will not result in any impacts related to erosion at the Landfall Site. Cable installed via HDD is planned for a depth of roughly 30 feet under the beach at the tideline.
4771.03/Vineyard Wind Connector 5-24 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. CR2.4 – Damage Prevention and Flood Minimization
To maintain the storm damage prevention and flood control functions of Land Subject to Coastal Storm Flowage (LSCSF):
(1) No activity within a V-Zone shall increase the existing site elevations; and
(2) No activity within a V- or A-Zone shall increase the velocity of flood waters or increase flows due to a change in drainage or flowage characteristics on the subject site, adjacent properties, or any public or private way; and
(3) Placement of fill in hydraulically-constricted areas shall not be permitted.
The Project will not change existing site elevations, nor will it alter existing drainage or flowage characteristics in the Project area. The Project does not involve any fill.
CR2.5 – Barrier Beaches, Coastal Dunes and Their Buffers
The Project is not located on barrier beaches or their associated buffers; therefore. The Project crosses through a very short section of dune located between the parking and street at Covell’s Beach. The dune will be restored to its original condition after installation of the transmission conduit.
CR2.6 – Coastal Banks and Their Buffers
The Project will not affect any Coastal Bank.
CR2.7 – Disaster within A- and V-Zones
Where fire, storm, or similar disaster has caused damage to or loss of buildings of greater than 50 percent of their assessed value in FEMA A- and V-Zones…
The Project does not involve reconstruction from disaster; therefore, this MPS does not apply.
CR2.8 – Public Infrastructure in Land Subject to Coastal Storm Flowage
No new non water-dependent public infrastructure or expansion of existing non water- dependent public infrastructure shall be made in LSCSF…
This Project does not involve non-water-dependent public infrastructure; therefore, this MPS does not apply.
4771.03/Vineyard Wind Connector 5-25 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. CR2.9 – Dredged Material
Wherever feasible, clean, compatible dredged material shall be used on public beaches. When infeasible, dredged material shall be reused within the same littoral cell to enhance storm damage prevention provided that public access is afforded in accordance with MPS CR1.2.
The Project does not involve reusing dredged material as beach nourishment, and this MPS does not apply.
CR2.10 – General Exceptions
Notwithstanding MPS CR2.1, CR2.3, CR2.4, and CR2.8, the following activities may be permitted provided the applicant demonstrates to the satisfaction of the Commission that best available measures are utilized to minimize adverse impacts on all critical characteristics of LSCSF, and provided that all other RPP MPS for underlying resource areas are met… (7) underground utility crossings that do not disturb protected resources.
As previously described, portions of the Project route, which can be classified as an underground utility crossing, are within LSCSF. However, the Project will not change existing site elevations within LSCSF, nor will it alter existing drainage or flowage characteristics in the Project area. The Project does not involve any fill, and will not alter the functions of LSCSF.
CR2.11 – Beach Nourishment Site Conditions
The applicant shall characterize the profile and sediment of the beach to be nourished, and shall demonstrate the compatibility of the grain size of the sediment source material and that of the receiving beach...
The Project does not involve beach nourishment; therefore, this MPS does not apply.
CR2.12 – Beach Nourishment – Site Monitoring
All DRI reviews of beach nourishment projects shall require a site monitoring plan as a condition of approval…
The Project does not involve beach nourishment; therefore, this MPS does not apply.
5.4.3 Goal CR3 – Coastal Water Quality and Habitat
Coastal Resources Goal CR3 is “[t]o maintain and improve coastal water quality in all coastal waters as appropriate, and to protect the health of coastal ecosystems.” Project consistency with the applicable MPS is discussed below.
4771.03/Vineyard Wind Connector 5-26 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. CR3.1 – Buffers to Coastal Wetlands
Undisturbed buffer areas of at least 100 feet surrounding coastal wetlands and/or landward of the mean high water mark of coastal water bodies shall be protected in accordance with MPS WET1.2.
There is no work proposed in any undisturbed buffers within 100 feet of coastal wetlands or the mean high water mark of coastal water bodies. All disturbances within buffers to coastal wetlands will be limited to paved road surfaces and road shoulders or paved parking areas. Impact to a small area of dune located between the parking lot and street at Covell’s Beach will be restored following construction.
CR3.2 – Septic Systems in V-Zones
New mounded septic systems shall be prohibited within FEMA V-Zones except to upgrade existing failed systems…
The Project does not involve septic systems; therefore, this MPS does not apply.
CR3.3 – Stormwater Discharges
No direct untreated stormwater discharges shall be permitted into any coastal waters or wetlands, including discharges above or below the mean high water level. New treated stormwater discharges shall be located a minimum of 100 feet from wetlands and water bodies, consistent with MPS WET1.4. For redevelopment, treated stormwater discharges shall be located a minimum of 100 feet, or the farthest distance practicable, from wetlands or water bodies. All stormwater discharge shall be consistent with MPS WET1.4.
There will be no new direct discharges of untreated stormwater as a result of the Project; stormwater management on the proposed substation site, which is not located within 100 feet of any wetland resource area, is described in the Stormwater Management Report provided as Attachment H. Stormwater management and erosion control during construction will be managed through BMPs that will be maintained throughout construction until any disturbed surfaces have been stabilized.
HDD is the proposed method for achieving the offshore-to-onshore transition at the Landfall Site. Land-based HDD rigs are typically staged behind an approach pit, which for this Project will measure approximately ten feet by ten feet and will be located within the paved parking lot. The approach pit will provide the contractor with access to the proper trajectory for drilling and will also serve as a reservoir for drilling fluids (i.e., a water-based slurry consisting predominantly of bentonite, a naturally-occurring, non-toxic clay) used to extract material from the drill head. BMPs including silt fence and/or hay bales will be placed around the reservoir pit. These siltation barriers will be monitored on a regular basis to ensure they function as intended.
4771.03/Vineyard Wind Connector 5-27 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. During HDD operations, slurry will be collected from the reservoir pit and will be processed through a filter/recycling system where drill cuttings (solids) will be separated from reusable drill fluid. Non-reusable material consisting of drill cuttings and excess drill fluid will be trucked to an appropriate disposal site. This material is typically classified as clean fill, and it is anticipated that will be the case for this Project. The material may have an elevated water content, which could require transport in sealed trucks. Typical disposal sites for this type of material include gravel pits or land farmed as upland field or pasture.
CR3.4 – Stormwater Management Designed to Accommodate Relative Sea-level Rise
The design and construction of stormwater management systems proposed within 300 feet of the spring high water contour shall…
The Project does not involve any stormwater management systems proposed within 300 feet of the spring high water contour; therefore, this MPS does not apply.
CR3.5 – Docks and Piers
In order to reduce cumulative adverse impacts to coastal ecosystems, community docks and piers, rather than separate structures serving individual lots, shall be required…
The Project does not involve construction or expansion of docks or piers; therefore, this MPS does not apply.
CR3.6 – New Marinas
New marinas of 10 or more slips, moorings, or active landward storage berths, and expansions of existing marinas by 10 or more slips, moorings, or berths shall…
The Project does not involve a marina; therefore, this MPS does not apply.
CR3.7 – Prohibition on Improvement Dredging
Improvement dredging shall be prohibited except when necessary to accomplish a substantial public benefit and no feasible alternative exists.
The Project does not involve improvement dredging; therefore, this MPS does not apply. The only dredging proposed for the Project is where the presence of large sand waves will require pre-cable-laying dredging to enable sufficient burial depth during cable installation. Due to the dynamic nature of sand waves driven by the strong tidal currents within Nantucket Sound, it is expected the sand waves will reform over the dredged area in a short time.
4771.03/Vineyard Wind Connector 5-28 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. CR3.8 – Maintenance Dredging
All projects proposed as maintenance dredging shall provide prior permitting authorities, permit numbers, dates of issuance and re-issuance, and documentation that clearly demonstrates the location, width, depth and length of the previously permitted project.
The Project does not involve maintenance dredging; therefore, this MPS does not apply.
CR3.9 – Beneficial Reuse of Dredged Material
Beneficial reuse of clean dredged materials associated with any development project shall be required, consistent with MPS CR2.9.
The Project does not involve beneficial reuse of dredged material; therefore, this MPS does not apply.
CR3.10 – Eelgrass
Development shall have no direct or indirect adverse effects to eelgrass beds, unless there is no feasible alternative location or design for the project and the project is necessary to accomplish an overriding public benefit. If a project adversely affecting eelgrass is permitted, the Commission shall require appropriate mitigation.
Eelgrass (Zostera marina) beds form an important habitat in the coastal environment that provides refuge and sustenance for a large number and variety of animals, as well as serving as a critical component of sediment and shoreline stabilization. The Project will completely avoid impacts to eelgrass bed.
Note that evaluations of submerged aquatic vegetation (SAV) within the cable corridor have included a desktop study making use of data from MassDEP’s Eelgrass Mapping Project, which, over multiple years, mapped eelgrass beds in state waters using high- resolution digital imagery and extensive fieldwork supported by high-accuracy GPS, high-resolution sonar, and underwater video cameras. Following incorporation of information from the desktop study, in November 2017 an eelgrass survey was conducted in Lewis Bay aimed specifically at historically mapped beds in the area. Several transects were strategically positioned around Egg island to address this question. The desktop study was also used to inform the location and extent of “Tier-1 SAV” on-site surveys which were conducted on July 12 and July 18, 2018. As described in Section 1.3.1.2 of the SDEIR, the on-site surveys determined the presence or absence of eelgrass and/or widgeon grass beds within pre-determined transect lines for four dive investigation areas along the cable corridor (see Section 1.3.1.2 of the SDEIR). These surveys were performed in conformance with guidance provided in Massachusetts Division of Marine Fisheries Technical Report TR-43, “Technical Guidelines for the Delineation, Restoration, and
4771.03/Vineyard Wind Connector 5-29 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. Monitoring of Eelgrass (Zostera marina) in Massachusetts Coastal Water”, dated October 2010, and the Joint Federal Regulatory Resource Agency’s Submerged Aquatic Vegetation Survey Guidance for the New England Region (June 21, 2011 Version).
The 2018 field campaign purposely revisited areas that had historically mapped eelgrass beds to further confirm or deny the existence and abundance of the habitat. Investigations in 2018 also infilled areas of the Offshore Export Cable Corridor where data was previously lacking. The 2018 survey data confirm that eelgrass can be avoided along the preferred Covell’s Beach route. The data also provides further information regarding the alternate New Hampshire Avenue route.
Underwater video was the primary tool used for identification and mapping of eelgrass beds, since the isolated, patchy nature of the eelgrass, where present, is not always detectable on sonar imagery (see Section 3.4.3 of Attachment E to the SDEIR). The side scan sonar records were reviewed initially in shallow areas exhibiting prime characteristics for sea grass development, with underwater video utilized to further ground-truth and confirm the presence or absence of the habitat. Towed underwater camera systems were used to more effectively and safely cover transects crossing the installation corridor and in specific locations where a higher potential for sea grass existed. Where eelgrass was documented by towed video, diver inspection of the seafloor using a handheld camera system was conducted to accurately map the areal extent of the beds and local abundance. This was only necessary offshore from Covell’s Beach at Spindle Rock. To the greatest extent possible given site conditions, the investigation followed technical guidelines for delineating sea grasses suggested by the DMF.2
In deeper water areas in both 2017 and 2018 video imagery, eelgrass strands were observed along several transects; however, these isolated occurrences were determined to be dead strands of grass that were drifting/floating and not rooted in the substrate. Drifting strands can become embedded in gravel, cobbles, and shells on the seafloor, giving the appearance of rooted plants. Water depths typically more than 26 to 33 feet (8-10 m), together with the dark brown-black coloration of the strands, offered evidence that these were dead, drifting plant material.
Another area of interest was uncovered from the 2018 video survey offshore from Covell’s Beach where sparse patches of eelgrass have been identified around Spindle Rock in Centerville Harbor. Video transects included as part of the 2018 survey initially
2 Evans and Leschen. 2010. Massachusetts Division of Marine Fisheries Technical Report TR-43, “Technical Guidelines for the Delineation, Restoration, and Monitoring of Eelgrass (Zostera marina) in Massachusetts Coastal Water”.
4771.03/Vineyard Wind Connector 5-30 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. documented their presence, and a subsequent diver investigation provided a thorough mapping of the area. This patch of eelgrass, which is co-located with hard bottom (a rock pile). Patches of grass intertwined with macroalgae inhabit the discontinuous sandy bottom in and around the rock pile. In contrast to the blades of dead eelgrass near Egg Island, these
exhibit the bright green coloring more common for healthy eelgrass during the growing season. An eelgrass survey report describing the occurrence of eelgrass in the vicinity of Spindle Rock was provided as Attachment P to the SDEIR.
The eelgrass is within the bounds of an OMP-mapped hard/complex bottom SSU that was confirmed during the 2018 surveys. As described previously and shown on Figure 2-1, the length and heading of the HDD from the Covell’s Beach paved parking lot has been refined to entirely avoid this SSU.
CR3.11 – Fish, Shellfish, Crustaceans
Development and redevelopment shall be designed and constructed to minimize direct and indirect adverse impacts to fish, shellfish, crustaceans and their habitat.
Shellfish suitability areas are described in Section 4.5.3.1 and, according to maps published by DMF, are shown on Figure 4-10 in Barnstable County waters in the Project vicinity. Offshore export cable installation through these areas will impact resident shellfish and will temporarily alter habitat. The Proponent has consulted with the shellfish constables in Barnstable, DMF, and members of the commercial bay scallop and whelk fishing communities. These consultations will continue and will be useful for determining appropriate mitigation that reflects the extent of impacts to the resources in question.
The Offshore Export Cable Corridor has been sited to avoid eelgrass beds and to limit impacts to other sensitive habitats to the greatest extent feasible, and population-level impacts to fish species are not anticipated. Commercial fishing may be temporarily affected in the immediate vicinity of construction activities, although no significant effects are anticipated along the Offshore Export Cable Corridor after construction is complete. Some localized changes may occur if cable protection is required in certain areas. The Company’s priority will be to achieve target burial depth of the two offshore export cables and to avoid the need for any cable protection. However, it is possible that achieving sufficient burial depth may be unsuccessful in areas where the seafloor is composed of consolidated materials, making complete avoidance of cable protection measures infeasible. In these cases, cable protection (e.g., a layer of rock or concrete “mattresses”) may be necessary. Rock placed for cable protection can function as good habitat for marine life, since it mimics natural hard/complex bottom. Nonetheless, Vineyard Wind is seeking to minimize the amount of cable protection required not only to avoid and minimize environmental impacts but also to reduce installation time and effort.
4771.03/Vineyard Wind Connector 5-31 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. Vineyard Wind will not restrict fishing or transit in the Project area, except for required temporary safety zones during construction or maintenance. Commercial fishing impacts will be further mitigated by ongoing communication via the Fisheries Communication Plan and the use of Fisheries Liaisons and Fisheries Representatives; the Fisheries Communications Plan is provided in Attachment I, and was reviewed by federal and state agencies (in Massachusetts and Rhode Island) as well as by stakeholders on Martha’s Vineyard, Cape Cod, and in New Bedford. The Fisheries Communications Plan is an evolving document and will be updated to address feedback received. In addition, Vineyard Wind is developing a framework for a pre- and post-construction fisheries monitoring program to measure the Project’s effect on fisheries resources. Vineyard Wind is working with the Massachusetts School for Marine Science and Technology (SMAST) and local stakeholders to inform that effort and design the study.
No permanent changes in bottom topography, water circulation, or water quality are anticipated as a result of cable installation activities, and short-term impacts from turbidity are expected to be slight. Existing organisms and habitat along the Offshore Export Cable Corridor are adapted to disturbances associated with active sediment transport and resuspension due to strong tidal currents. Thus, it is anticipated they will quickly adjust to the temporary disturbance from the cable burial. Also, reflecting the dynamic tidal currents in the area, bottom sediments along the proposed route are primarily sand and gravel, and as a result they can be assumed to resettle quickly after disturbance.
The Proponent engaged Swanson Environmental Associates and RPS to perform a sediment dispersion modeling study of offshore cable installation activities. That study was performed in support of the Vineyard Wind project’s federal permitting process led by the Bureau of Ocean Energy Management (BOEM), and was included as a technical appendix to that project’s Construction and Operations Plan (COP). As a result, the study includes some areas outside of Barnstable County or Massachusetts jurisdiction, such as those related to the inter-array cables proposed within the Wind Development Area (WDA) in federal waters. Nonetheless, the study in its entirety was included as Attachment J to the SDEIR that the Proponent has provided to the CCC and which is incorporated into the record here.
As shown in the sediment dispersion modeling study that was provided as Attachment J of the SDEIR and is summarized in Section 4.5.3.2, in general the plume from jet-plow installation as delineated by excess suspended sediment concentrations greater than 10 mg/L typically extended less than 656 feet (200 m) from the route centerline, though did extend up to ~1.2 miles (~2 km) in some places. Further, the excess concentrations were confined to the lower portion of the water column, and resettled rapidly (within 4-6 hours) due to the high proportion of coarse sand throughout the route. Therefore, these concentrations and durations of exposure are below those causing sublethal or lethal effects to benthic organisms. Simulations of cable installation, both with and without jetting for sand wave clearance, using typical installation parameters showed that deposition greater
4771.03/Vineyard Wind Connector 5-32 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. than 1 mm occurred within 262-328 feet (80-100 m) of the route centerline. In general, the total set of sediment grain size distribution analysis showed that the samples were predominantly coarse sand per the model classification scheme with some exceptions.
Furthermore, the modeling demonstrates that deposition greater than 20 mm will only result from the dumping activities by the trailing suction hopper dredge (TSHD). Dredging will only occur within mobile sand waves, and dumping from the TSHD will also only occur within areas of mobile sand waves, which are less suitable shellfish habitat. Furthermore, no areas of deposition greater than 20 mm will result from typical cable installation activities (e.g., jet-plow, mechanical trencher) (see Section 4.5.3.2).
CR3.12 – Aquaculture
Coastal aquaculture shall be designed to have no significant adverse impacts to water quality or marine habitat…
The Project does not involve aquaculture; therefore, this MPS does not apply.
CR3.13 – Waterfront-fueling Facilities
Waterfront-fueling facilities are encouraged to be upgraded to ensure that best management practices are used to avoid adverse impacts to water quality.
The Project does not involve a waterfront-fueling facility; therefore, this MPS does not apply.
5.5 Marine Resources
The Marine Resources section of the RPP contains the goals and policies for preserving marine resources.
5.5.1 Goal MR1 – Offshore Sand Mining and Conduits
Goal MR1 is “[t]o preserve and manage marine resources so as to safeguard and perpetuate their ecological, economic, historic, maritime, and aesthetic values, and where appropriate, to allow for limited development activities compatible with resource preservation interests.” Project consistency with the applicable MPS is discussed below.
MR1.1 – Prohibited Areas, Sand Mining
Sand and gravel mining operations shall be located outside of Sand and Gravel Mining Prohibited Areas as defined and illustrated on the Cape Cod Ocean Management Plan Sand and Gravel Mining Prohibited Areas Map.
4771.03/Vineyard Wind Connector 5-33 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The Project does not involve sand and gravel mining; therefore, this MPS does not apply. It is worth noting, however, that the potential sand wave dredging activities are not located within the RPP’s Sand and Gravel Mining Prohibited Areas, which are primarily constrained to the Cape Cod Ocean Sanctuary and areas within Massachusetts Bay.
MR1.2 – Prohibited Areas, Cables/Pipelines
Cable or pipeline installations shall be located outside of Cable/Pipeline Prohibited Areas as defined and illustrated on the “Cape Cod Ocean Management Plan Cable/Pipeline Prohibited Areas Map”.
The Project is not located within Cable/Pipeline Prohibited Areas, which are primarily constrained to the Cape Cod Ocean Sanctuary and areas within Massachusetts Bay.
MR1.3 – Buffers to Navigation
Sand Mining and cable/pipeline installations shall have buffers to established ferry routes, navigational channels, and commercial shipping lanes with adequate width to prevent accidents or irreconcilable conflict between different uses… Cable and pipeline installations may be sited coincident with established navigational routes provided an applicant can provide evidence that the proposed installation will not adversely impact established navigational uses.
Vineyard Wind is not proposing any restrictions on navigation, although construction and installation activities may temporarily affect navigation in the immediate vicinity of construction vessels. During the construction and installation phase, Vineyard Wind will employ a Marine Coordinator to manage all construction vessel logistics and act as a liaison with the USCG, port authorities, state and local law enforcement, marine patrol, and port operators. The Marine Coordinator will keep informed of all planned vessel deployment and will manage the Project’s marine logistics and vessel traffic coordination between the staging ports and the Wind Development Area in federal waters. Vineyard Wind has also engaged with the Northeast Marine Pilots Association to coordinate construction and installation vessel approaches to the Project region, as required by state and federal law, and to minimize impacts to commercial vessel traffic and navigation.
Once installed, the offshore export cables will not affect navigation, including navigation directly over the area where the cables are installed.
MR1.4 – Operations and Maintenance Plan
Applicants shall provide an Operations and Maintenance Plan for Commission review and consideration for approval. The Operations and Maintenance Plan shall identify the party(ies) responsible for ensuring (a) that the Development activity is operated and maintained so as to not constitute a significant threat to the public health and safety and the environment; (b) that adequate capital or insurance exists to make necessary repairs,
4771.03/Vineyard Wind Connector 5-34 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. including repairs on account of accidents, collision, and natural disasters; and (c) that all performance standards set forth herein will be met (e.g., TOY restrictions). Such Operations and Maintenance Plan shall include provisions for annual review by the Commission, and the Commission shall require a Certificate of Compliance to ensure reporting is submitted in a timely manner.
Offshore and nearshore geophysical surveys will be conducted post-construction during the operations and maintenance phase of the Project to inspect cable depth of burial and conduct as-built cable surveys. In addition, it is anticipated that short ad-hoc geophysical or geotechnical surveys may be required during construction to verify site conditions. Geotechnical work would only be conducted in areas already cleared for archaeological resources. Any unanticipated discoveries of cultural resources will be reported and avoided during further onsite work, with review and recommendations by the qualified marine archaeologist and as agreed during the Section 106 consultation.
All surveys will use BMPs and industry-standard equipment that has been approved for use previously for offshore renewable energy work. Most of the surveys are expected to entail use of geophysical systems 200 kHz or higher in frequency that do not require any special mitigation (e.g., multi-beam echosounder, side scan sonar, and magnetometer). Standard operating conditions (e.g., vessel strike avoidance, separation distances from protected species, necessary notifications, marine trash and debris prevention) for work will be observed.
For surveys using sonar equipment less than 200 kHz in frequency (sub-bottom profilers) and any bottom-disturbing investigations that have been previously cleared, in addition to the standard operating procedures identified above, the following mitigation measures will be employed to maintain a level of consistency with offshore project activities:
♦ Notifications when appropriate: national security and military organizations, USCG communication, tribal correspondence. ♦ Vessel strike avoidance measures. ♦ Protected Species Observer monitoring: Protected Species Observers will accompany survey vessels and follow standard monitoring protocols, actively observing an established clearance zone around each vessel. ♦ The use of passive acoustic monitoring (PAM). ♦ Shut down and soft start procedures.
After the initial post-construction surveys, bathymetric and other surveys and monitoring of cable burial depth will be performed routinely.
4771.03/Vineyard Wind Connector 5-35 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. Once installed, there are no operational parameters necessary for proper cable functioning with the exception of any repairs that are necessary due to unforeseen damage to the cable. Since the proposed installation involves burying the cable, the risk of damage is slight. Nonetheless, in case of a cable fault, repair operations would have to be undertaken. If the fault occurs in deep water, the repair can be performed using a jetting device to expose the cable, at which point the cable would be repaired and reinstalled in place. If the fault occurs in shallower water (i.e., at depths of less than approximately 30 feet [10 meters]), repair operations could utilize a local barge and diving crew to approach the cable area, use jet lances to expose the cable, then pull the cable onto the barge using a chain or rope. The cable would then be repaired onboard the barge, re-lowered to the seabed, and hand- jetted back under the seafloor. The area of impact would be constrained to the location of the fault and immediately surrounding cable.
MR1.5 – Emergency Response Plan
Applicants shall provide an Emergency Response Plan for Commission review and consideration for approval. The Emergency Response Plan shall identify responsible parties for first response and ongoing disaster management from events including, but not limited to, fire, collision, catastrophe, oil spills, and other hazardous materials leaks, or poor water quality or sedimentation resulting from mining operations or conduit installation. The Emergency Response Plan shall require the timely and competent response to accidents or disasters so as to minimize to the greatest extent practicable threatened or actual harm to the public and damage to the environment.
The offshore and onshore export cables proposed for this Project pose no risk of hazardous materials release, fire, water quality impacts, or collision that would damage any marine vessels. Furthermore, the degree of any risk associated with materials release or water quality impact is very slight during cable installation as well. The draft CMP provided as Attachment C of the DEIR contains assurances and measures that will govern the construction and installation of the proposed cable to avoid and minimize such risks. As described in that Plan, compliance with permits and mitigation requirements will be monitored during construction by an Environmental Monitor who will be independent of the Contractor and will report directly to the Company. The Environmental Monitor(s) will be responsible for working with the Company, Construction Contractor supervisors, and construction personnel to ensure proper protection of sensitive environmental resources in the Project area and awareness of environmental permit requirements and provisions of the Plan. This inspector will have access to the Proponent’s Construction Supervisor and will have "stop work" authority for work activities out of compliance with the CMP or related environmental permits.
At the proposed substation, the substation design includes an integrated fluid containment system capable of capturing the full volume (110%) of dielectric fluid from all substation components plus an additional volume to account for a simultaneous 100-year, 24-hour rainfall event (please see the response to MPS WR1.2). While sumps for transformers are
4771.03/Vineyard Wind Connector 5-36 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. standard practice, they are not normally used for other lower-volume fluid-filled equipment given the low probability of any leakage. However, the Proponent has opted to commit to such containment at this time, given the sensitive nature of the Cape Cod watershed and based on consultations with local officials and comments at public meetings.
MR1.6 – North Atlantic Right Whale
Sand Mining operations and cable/pipeline installations shall not be permitted from January to May in North Atlantic Right Whale Critical Habitat (comprising all of Cape Cod Bay due north and east of the Cape Cod Canal, as designated by National Marine Fisheries Service (NMFS)). Sand Mining operations and cable/pipeline installations anywhere in Barnstable County shall immediately cease if North Atlantic Right Whale(s) are observed within two (2) miles of such activities. The sighting shall immediately be reported to NMFS by calling 978-585-8473 or by contacting the U.S. Coast Guard via channel 16. Activities shall not recommence until such time that NMFS or a NMFS-approved environmental monitor provides written notification of their determination that operations may resume.
The Offshore Export Cable Corridor avoids OMP-mapped core habitat of the North Atlantic Right Whale. Furthermore, the Proponent will abide by these notification requirements should a North Atlantic Right Whale be observed. Measures to avoid and minimize impacts to marine mammals are addressed in Section 4.5.2.4.
MR1.7 – North Atlantic Right Whale, TOY Restrictions
Sand Mining operations and cable/pipeline installations shall not be permitted from January to May in the Exclusionary Areas that comprise expanded North Atlantic Right Whale habitat (see Cape Cod Ocean Management Plan Map of Exclusionary Areas). Sand Mining operations and cable/pipeline installations may be permitted in these Exclusionary Areas at other times of year provided the applicant can demonstrate through the provision of clear and convincing evidence that the activity will not cause direct or indirect impacts to North Atlantic Right Whales, or other whale species.
The Project is not located within the Exclusionary Areas that comprise expanded North Atlantic Right Whale habitat as defined on the Cape Cod Ocean Management Plan Map of Exclusionary Areas; therefore, this TOY restriction is not applicable.
MR1.8 – Whales
To reduce the potential for vessel harassments or collisions with listed whales and sea turtles, all vessel and aircraft captains and project managers associated with the Development activity shall be familiar with the NOAA Fisheries Northeast Regional Viewing Guidelines, as updated, and MMS Gulf of Mexico Region’s Notice to Lessee (NTL) No. 2007-G04 – Vessel Strike Avoidance and Injured/Dead Protected Species Reporting
4771.03/Vineyard Wind Connector 5-37 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. guidelines, http://www.nero.noaa.gov/prot_res/mmv/regs.html. The Commission shall require the Applicant to verify it has distributed these guidelines to those individuals responsible for operating and managing the Development.
The Proponent acknowledges and will comply with these requirements. Due to the extremely slow speed of installation vessels, impacts to whales in Barnstable County waters are not expected.
MR1.9 – Sea Turtles
Sand Mining operations and cable/pipeline installation shall protect sea turtles. The applicant shall provide a species protection plan to the Commission for its review and approval that accounts for development that is proposed within sea turtle habitat or during times of year when turtles are present. The Commission may consult with the NMFS or DMF in review and approval of a species protection plan.
Four species of turtles may occur in the Project area: Loggerhead Sea Turtle (Caretta caretta), Kemp’s Ridley Sea Turtle (Lepidochelys kempii), Green Sea Turtle (Chelonia mydas), and Leatherback Sea Turtle (Dermochelys coriacea). The presence of sea turtles in the Project area is primarily limited to summer and fall months, and no nesting sites are expected near the Landfall Site. The Project is located in an area that lacks critical sea turtle habitat, and the Landfall Site and onshore facilities are not located near known sea turtle nesting beaches. Avoidance, minimization, and mitigation measures employed for marine mammals are also applicable to sea turtles. Note that cable laying operations proceed at a very slow speed (less than one knot per hour).
MR1.10 – Fish Resources and Habitat
Sand Mining operations and cable/pipeline installation shall protect important fish resources and habitat as classified by the Division of Marine Fisheries, including diadromous fish runs and shellfish habitat. Sand Mining operations and cable/pipeline installation may be permitted in Exclusionary or Provisional areas, provided that the presumption of a site’s importance to fish resources and habitat is overcome where the applicant demonstrates to the satisfaction of the Commission through a site assessment that the resources do not exist, or the site is not significant to important fish resources and habitat. In addition, Sand Mining operations and cable/pipeline installation shall avoid licensed commercial fishing or aquaculture installations (e.g. fish weirs, aquaculture pens, rafts, floats, etc.).
The Project is not located in any Exclusionary or Provisional areas. As described in Section 4.5.3.1, the Offshore Cable Export Corridor will cross areas mapped as significant shellfish habitat within state waters. However, no permanent changes in bottom topography, water circulation, or water quality are anticipated as a result of cable installation, and any construction-related impacts will be temporary. TOY restrictions are discussed in Section 4.5.4.
4771.03/Vineyard Wind Connector 5-38 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. There are aquaculture grant areas in Nantucket Sound that are used for mussel culture and kelp production. These grants are located near the eastern extent of Horseshoe Shoal and are far removed from the Project’s export cable corridor. Given this large separation, cable installation will not result in any impacts to the Nantucket Sound aquaculture grants.
MR1.11 – Benthic Habitats, Direct Impacts
Sand Mining operations and cable/pipeline installation shall not have any direct impacts on eelgrass beds or areas of other biologically productive benthic habitats (e.g., hard/complex seafloor). The burden of proof shall be on the applicant to demonstrate through field surveys that the resources are not present, and/or will not be impacted adversely. Sand Mining operations and cable/pipeline installation shall avoid impacts to areas of historic eelgrass beds to the maximum extent feasible, regardless of whether eelgrass is found in the historic eelgrass bed at the time of application.
Eelgrass beds and hard/complex bottom are both identified in the Massachusetts Ocean Management Plan (OMP) as Special, Sensitive, and Unique (SSU) resources for cable projects.
Within Barnstable County, isolated hard bottom areas are present in the northern portion of Nantucket Sound within the Offshore Export Cable Corridor (see Figure 2-2). These include scattered and piled boulders around charted features such as Collier Ledge, Gannet Rocks, and Spindle Rock toward/in Centerville Harbor and Gardiners Rock south of the Hyannis Harbor entrance.
Together with the flat sandy seafloor, bedform fields (i.e., ripples, megaripples, and sand waves) cover the most area within the Offshore Export Cable Corridor. Size and wavelength vary considerably throughout, ranging from less than 1 foot (0.3 m) to over 30 feet (9 m) in relief, with wavelengths of less than 6.5 feet (2 m) to over 410 feet (125 m). Due to the mobility of the sediments in this habitat, development of infaunal communities is greatly reduced compared to more stable seabed areas. While this equates to a lower productive infaunal benthic regime, the bottom morphology and dynamics of the fields is reportedly attractive to finfish (personal communication, Commonwealth of Massachusetts). The areal extent of these bedforms (i.e., complex bottom) is constantly changing with subtle environmental shifts in water depths, sediment grain size, and current flow. This is a laterally extensive habitat due to the predominantly sandy seafloor and tidal currents flowing over the bottom and constantly reworking sediment.
At isolated locations, where large sand waves exhibit greater than 5 feet (1.5 m) of relief above the bedform troughs to either side, dredging of the top portion of the sand wave may be necessary to allow the cable installation tool to reach the stable sediment layer under the base of the mobile sand unit/habitat. The temporary displacement of this material from the top of the bedforms in a limited swath along the installation corridor is believed to be of minimal and short-term impact to the habitat due to mobility of the surficial sand layer,
4771.03/Vineyard Wind Connector 5-39 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. which migrates daily with the tidal currents, and the low productivity of the benthic habitat. The disturbed bedform will evolve back to its original morphology over a relatively short time period, dependent upon the tidal forces and resulting sand migration rates for that specific location. Results from the 2017 and 2018 marine surveys were included in Section 1.3.1 and Attachment E of the Proponent’s SDEIR that was provided to the CCC and is incorporated into the record of this DRI filing.
Eelgrass resources in the Project area are described in the response to MPS CR3.10. The only area of eelgrass beds in the Offshore Export Cable Corridor is co-located within an area of hard bottom offshore of the Covell’s Beach Landfall Site. The length and heading of the HDD from the Covell’s Beach paved parking lot will enable the Project to entirely avoid impacts to the eelgrass and the surrounding hard/complex bottom.
MR1.12 – Benthic Habitats, Indirect Impacts
Applicants for proposed Sand Mining operations or cable/pipeline installation located within 500 feet of eelgrass beds or other biologically productive benthic habitats (e.g., Hard/Complex Seafloor) shall provide an analysis of anticipated sediment dispersion resulting from development activities. The results of the sediment dispersion modeling shall be used to condition any approval to ensure that the design and siting of sand mining operations and cable/pipeline installation avoids indirect impacts (e.g., turbidity) to eelgrass and other biologically productive benthic habitats (e.g., Hard/Complex Seafloor). Best construction practices (e.g., directional drilling shall be used to the extent feasible.
As described previously under CR3.10 and shown on Figure 2-2, the Project will have no impacts to eelgrass beds, and the export cables will be installed more than 500 feet east of the only areas of eelgrass beds identified offshore from Covell’s Beach in the vicinity of Spindle Rock.
As summarized in Section 4.5.3.2, the Company engaged Swanson Environmental Associates and RPS to perform a sediment dispersion modeling study of offshore cable installation activities. Impacts are expected to be minor and of short duration, and recolonization and recovery to pre-construction species assemblages is expected given the similarity of nearby habitat and species. Nearby, un-impacted areas will likely act as refuge areas and supply a brood stock of species, which will begin recolonizing disturbed areas post-construction. Note that particle sediment monitoring studies completed for the Block
4771.03/Vineyard Wind Connector 5-40 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. Island Wind Farm’s offshore cable installation found that displaced sediments were an average distance from the trench centerline of 12.5 feet (3.8 meters) at a thickness 2.8 inches (7 cm).3
MR1.13 – Benthic Habitats, TOY Restrictions
The applicant shall consult with Massachusetts Division of Marine Fisheries in determining whether restrictions shall be placed on the timing or methods of sand mining operations and cable/pipeline installations to avoid temporary or permanent impacts to critical life history stages (e.g., spawning, and egg, embryo, and juvenile development) of marine species. Best management practices shall be employed during development activities to minimize turbidity and sedimentation impacts to sensitive benthic habitats, including eelgrass and other biologically productive benthic habitats (e.g., hard/complex seafloor).
The Offshore Export Cable Corridor has been sited to avoid eelgrass beds and to limit impacts to other sensitive fishery habitats to the greatest extent feasible. Nevertheless, fish species and habitats may be temporarily affected by suspended sediments and siltation during cable installation. TOY restrictions are discussed in Section 4.5.4.
The Proponent has selected installation techniques that will minimize the level of seafloor disturbance during installation of the export cables. Perhaps most importantly, the alignment of the Offshore Export Cable Corridor is the product of an extensive consideration of alternatives, and is itself intended to avoid and minimize potential impacts to sensitive resources, including SSU areas such as eelgrass beds and hard/complex bottom. The Proponent engaged Swanson Environmental Associates and RPS to perform a sediment dispersion modeling study of offshore cable installation activities, which was included as Attachment F in the SDEIR that the Proponent has provided to the CCC and which is incorporated into the record here. Increased turbidity and possible siltation during installation of the export cables is expected to be of relatively minor and of short duration, since the majority of the Offshore Export Cable Corridor will pass through coarse-grained sediment that will quickly settle out of the water column.
MR1.14 – Monitoring of Benthic Habitats during Construction
Applicants for sand mining operations and cable/pipeline installations shall provide a site monitoring plan for Commission review and approval. In order to evaluate project impacts, including any changes in the areal extent and health of sensitive marine resources, such plan shall identify (a) sensitive marine resources in the vicinity of the construction site, (b)
3 James Elliott, K. Smith, D.R. Gallien, and A. Khan. 2017. Observing Cable Laying and Particle Settlement During the Construction of the Block Island Wind Farm. Final Report to the U.S. Department of the Interior, Bureau of Ocean Energy Management, Office of Renewable Energy Programs. OCS Study BOEM 2017-027. 225 pp.
4771.03/Vineyard Wind Connector 5-41 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. protocols to monitor turbidity, light penetration, dissolved oxygen and nutrient conditions in the proposed construction area, as well as within a buffer zone that extends to the furthest boundary of the potentially affected adjacent area (as determined by current/wave modeling), (c) monitoring schedules, and (d) contingency plans if turbidity conditions exceed identified thresholds.
The Commission shall require Certificates of Compliance at appropriate intervals to ensure the provisions of the monitoring plan are met.
Water quality related to suspended sediments from cable installation, dredging and other construction activities, as appropriate, will be monitored. Details of the monitoring effort will be developed with the appropriate state and federal agencies (MassDEP 401 Regulatory Program and the U.S. Army Corps of Engineers [USACE]) during other permitting processes. The monitoring is anticipated to consist of using a hand-held or similar turbidity sensor deployed from a small vessel to collect turbidity readings from multiple depths within the water column. If determined to be appropriate, collection of water samples for subsequent analysis for total suspended solids (TSS) could be made from the vessel to quantify the sediment concentration in the plume. Background levels outside of the plume for turbidity (and TSS, if appropriate) could also be acquired.
Offshore and nearshore geophysical surveys will be conducted post-construction during the operations and maintenance phase of the Project to inspect cable depth of burial and conduct as-built cable surveys. In addition, it is anticipated that short ad-hoc geophysical or geotechnical surveys may be required during construction to verify site conditions. Geotechnical work would only be conducted in areas already cleared for archaeological resources. Any unanticipated discoveries of cultural resources will be reported and avoided during further onsite work, with review and recommendations by the qualified marine archaeologist and as agreed during the Section 106 consultation.
Vineyard Wind has also assembled a Benthic Habitat Monitoring Plan (included in Attachment J) that is intended to document habitat and benthic community disturbance and recovery as a result of construction and installation.
All surveys will use BMPs and industry-standard equipment that has been approved for use previously for offshore renewable energy work. Most of the surveys will entail use of geophysical systems 200 kHz or higher in frequency that do not require any special mitigation (e.g., multi-beam echosounder, side scan sonar, and magnetometer). Standard operating conditions (e.g., vessel strike avoidance, separation distances from protected species, necessary notifications, marine trash and debris prevention) for work will be observed.
4771.03/Vineyard Wind Connector 5-42 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. For surveys using sonar equipment less than 200 kHz in frequency (sub-bottom profilers) and any bottom-disturbing investigations that have been previously cleared, in addition to the standard operating procedures identified above, the following mitigation measures will be employed to maintain a level of consistency with offshore project activities:
♦ Notifications when appropriate: national security and military organizations, U.S. Coast Guard communication, tribal correspondence.
♦ Vessel strike avoidance measures, including speed restrictions in Dynamic Management Areas and from November 1 through July 31.
♦ Protected Species Observer monitoring: Protected Species Observers will accompany survey vessels and follow standard monitoring protocols, actively observing an established exclusion zone around each vessel.
♦ Shut down and soft start procedures.
After the initial post-construction surveys, bathymetric and other surveys and monitoring of cable burial depth will be performed routinely. The Company estimates these surveys will be performed every three years along the Offshore Export Cable Corridor.
MR1.15 – Rare Species Habitat
Applicants for sand mining operations or cable/pipeline installations within habitats critical to the survival of rare animals and plants shall submit the development proposal to the Massachusetts Natural Heritage and Endangered Species Program for review and comment. Development that would adversely affect habitat of local populations of rare wildlife and plants shall not be permitted. Development may be permitted where the proponent can demonstrate that such development will not adversely affect such habitat. A wildlife and plant habitat management plan may be required as a condition of approval when development or redevelopment is permitted in critical wildlife and plant habitat areas.
Please refer to Section 4.3.1 for a description of NHESP consultations.
MR1.16 – Construction Noise
Applicants shall provide a Construction Noise Mitigation Plan to the Commission for review and approval. Such plan shall address issues to avoid or minimize construction noise impacts on marine mammals and sea turtles, including but not limited to an assessment of the construction noise impacts on marine life, a monitoring plan for tracking marine mammals and sea turtles entering the construction zone, and a mitigation plan, including TOY restrictions on construction, to avoid or minimize construction noise impacts on marine mammals and sea turtles.
Cable laying activities will not constitute a significant source of noise.
4771.03/Vineyard Wind Connector 5-43 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. MR1.17 – Cumulative Impacts
As part of the application for offshore development, the cumulative impacts of any existing or permitted offshore WECFs, sand mining operations, and cables and pipelines within Barnstable County shall be considered. Applicants shall identify on a map all of the existing or permitted offshore WECFs, ongoing or prior sand mining operations, or cable or pipeline installations within Barnstable County, and the Commission shall determine whether the public benefits of the development outweigh the cumulative adverse impacts to resources protected under the Act.
Five existing submarine cables cross Nantucket Sound: three connect Martha’s Vineyard to the mainland, and two connect Nantucket to the mainland. These cables are shown on the Existing Conditions map provided as Figure 3-1 of the DEIR. The Proponent is not aware of any other offshore cables permitted to be installed within Nantucket Sound.
Following offshore cable installation, due to the target burial depth, Vineyard Wind is not proposing any restrictions on navigation, fishing, or the placement of fixed or mobile fishing gear.
An extensive discussion of Project benefits is provided in Section 2.5. The Project’s numerous and significant environmental and economic benefits clearly outweigh the temporary construction-period impacts associated with offshore export cable installation.
MR1.18 – Coordinated Conduit Crossings
Applicants shall coordinate conduit installations with existing cable or pipeline routes to the maximum extent feasible in order to minimize harm to the environment.
The Project does not involve the crossing of any existing submarine cable or pipeline.
MR1.19 – Archaeological Resources
Where Development is proposed on or adjacent to known archaeological sites or sites with high archaeological sensitivity as identified by the Massachusetts Board of Underwater Archaeological Resources and/or the Massachusetts Historical Commission, it shall be configured to protect such resources. Applicants shall conduct a predevelopment investigation of such sites early in the site planning process to serve as a guide for layout of the Development.
Vineyard Wind contracted with Gray & Pape Inc. to provide archaeological support for high-resolution geophysical marine surveys and subsequent geotechnical activities along the Offshore Export Cable Corridor. This research was conducted in conjunction with Alpine Ocean Seismic Surveys Inc. and Fugro Marine Geoservices, Inc.
4771.03/Vineyard Wind Connector 5-44 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. Archival and document research and field investigations were conducted as part of the cultural resource examination, and background research included a review of historic documents, previous research reports, a site file check, shipwreck inventories, secondary sources, and historic map analysis. Materials from archives at the Massachusetts Board of Underwater Archaeological Resources (MBUAR) were accessed. These data assisted in validating the geophysical data and interpretations. Field investigations included a marine high-resolution geophysical survey utilizing magnetometer, side scan sonar, sub-bottom profiler, and a multibeam unit. Bottom grabs and vibracores were also collected.
Documentary and field research results show the Offshore Export Cable Corridor has limited potential for human activity over time with sea level rise.4 During the pre-contact era, the entire region was subaerial only during the Paleoindian Period (approximately 12,000 years ago). Marine transgression rapidly covered the land during the Archaic Period and by the dawn of the Woodland Period (between approximately 500 BC and 1100 AD) only a small portion of the area would have been habitable.
As discussed in Section 4.9.2, offshore surveys in 2018 extended seafloor and subsurface coverage in all areas where bottom disturbance could occur during construction activities. Survey line spacing, coverage, geophysical system parameters, and methodologies were discussed with the Massachusetts Ocean Team and complied with BOEM geophysical and geotechnical as well as archaeological guidelines applicable to this Project. The Company’s marine archaeology consultant, Gray & Pape, is still in the process of acquiring data collected during the Project’s 2018 marine geophysical and geotechnical surveys. The analysis is ongoing, and when a draft archaeological report for marine aspects of the Project is complete, it will be submitted to MHC for review and comment.
Avoidance, minimization, and mitigation measures for terrestrial and submarine historical and archaeological resources within the Project area will be determined in consultation with MHC and MBUAR through the Section 106 process.
MR1.20 to 1.26 – Sand Mining
MPS MR1.20 through 1.25 apply to all sand mining projects. Since the proposed Project does not involve sand mining, these MPS are not applicable.
MR1.27 – Benthic Communities
Cable and pipeline installations shall not result in adverse impacts to benthic communities and their ecology, including finfish, shellfish, and migratory species habitat, including but not limited to, sedimentation, erosion, scour, or barriers to migration.
4 Note this is historical sea level rise over thousands of years, not recent sea level rise
4771.03/Vineyard Wind Connector 5-45 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The Company’s marine surveys demonstrate that the Offshore Export Cable Corridor will avoid eelgrass beds and will avoid and minimize impacts to hard/complex bottom, which of which are SSU areas defined in the Massachusetts OMP and are considered high-value benthic habitats. The Offshore Export Cable Corridor will pass through some areas that exhibit sand waves, and although these features provide high rugosity in the form of bathymetric relief, they are highly dynamic features that are in constant migration, and hence do not provide high-value benthic habitat.
Suspended sediment and sedimentation are described in Section 4.5.3.2 in the context of the Company’s sediment dispersion modeling study. Recolonization and recovery to pre- construction species assemblages is expected given the similarity of nearby habitat and species. Nearby, un-impacted areas will likely act as refuge areas and supply a brood stock of species, which will begin recolonizing disturbed areas post-construction. See also Section 4.5.
MR1.28 – Coastal Waterbirds
Cable/pipeline installations shall ensure that the core habitats of Long-tailed Duck, Roseate Tern, Special Concern Tern species (Arctic, Least, and Common Terns), and important nesting habitats of colonial waterbirds and Leach’s Storm Petrel are protected. Cable/pipeline installations may be permitted where the proponent can demonstrate that such Development will not adversely affect the habitat of these species. A species protection plan may be required as a condition of approval when cable/pipeline installation is permitted in these core habitats.
The proposed duct bank route and Landfall Site avoid Priority Habitat of state-listed rare species. Offshore, the NHESP has mapped all state waters within Nantucket Sound and Muskeget Channel as Priority Habitat of state-listed rare species (Massachusetts Natural Heritage Atlas, 14th Edition, 2017). As a result, the Offshore Export Cable Corridor will necessarily cross priority habitat within state waters. NHESP has determined that the Project’s offshore transmission is within the habitat of state listed migratory birds including Least Tern (Sternula antillarum), Common Tern (Sterna hirundo), Piping Plover (Charadrius melodus), and Roseate Tern (Sterna dougallii), which is also a federally-listed species.
As noted in Section 4.3.1.1, as is the case with all vessel traffic, including existing vessel traffic, some marine birds may be disturbed by vessels engaged in construction activities, which may lead to temporary displacement during cable installation or in a very rare instance a bird may collide with lighted vessels during low-light conditions. There is very low probability of any impact due to the temporary nature of cable-laying activities; at the very most vessels will be active for several weeks.
4771.03/Vineyard Wind Connector 5-46 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. 5.6 Wetlands
The Natural Systems section of the RPP contains the goals and policies applicable to wetlands on the Cape. Project consistency with the applicable goals and MPS related to wetlands is addressed below.
5.6.1 Goal WET1 – Wetlands Protection
Goal WET1 is “[t]o preserve and restore the quality and quantity of inland and coastal wetlands and their buffers on Cape Cod.” Project consistency with the applicable MPS is discussed below.
WET1.1 – Wetlands
Wetland alteration shall not be permitted except as provided herein and in MPS WET1.3. As an exception, where there is no feasible alternative, water-dependent projects involving wetland alteration with appropriate mitigation may be permitted subject to the approval of all permitting authorities. Such permission may be granted subject to a finding that there is no feasible alternative location for the project and that any necessary alteration is the minimum necessary to accomplish the goals of the project. Appropriate mitigation shall not include wetland creation or replication.
The proposed onshore duct bank will not impact any wetland resources except for temporary construction-period impacts to Land Subject to Coastal Storm Flowage (LSCSF). Installation of onshore transmission within paved roadways in LSCSF will require only temporary disturbance to the resource.
As a water-dependent project, it is necessary for the offshore export cables to be installed within wetlands. The Vineyard Wind Connector is presumptively water-dependent: the Massachusetts regulations at 310 CMR 9.12(2)(e), provide that “in the case of a facility generating electricity from wind power (wind turbine facility) or any ancillary facility therefore, for which an EIR is submitted, the Department shall presume such facility to be water dependent if the Secretary has determined that such facility requires direct access to or location in tidal waters.”
As a transmission project designed to connect infrastructure in an offshore Wind Development Area located in federal waters to an interconnection point on shore that is part of the regional electric grid, the Vineyard Wind Connector must necessarily cross flowed tidelands and cannot be located away from those tidelands while achieving the expressed Project purpose.
Nonetheless, the Project’s construction-related impacts will be temporary, and no permanent changes in bottom topography, water circulation, or water quality are anticipated as a result of the Project. As discussed in Section 3.1.5, cable protection may be
4771.03/Vineyard Wind Connector 5-47 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. needed in some locations where it is not possible to achieve sufficient burial depth. Vineyard Wind is seeking to minimize the amount of cable protection required not only to avoid and minimize environmental impacts but also to reduce installation time and effort.
In addition, the Project is an underground utility line allowable pursuant to MPS WET1.3, below.
WET1.2 – Wetland Buffers
Vegetated, undisturbed buffer areas of at least 100 feet in width shall be maintained and/or provided from the edge of coastal and inland wetlands including isolated wetlands, to protect their natural functions. This standard shall not be construed to preclude pedestrian access paths, vista pruning, or construction and maintenance of water-dependent structures within the buffer area, any of which may be permitted at the discretion of permitting authorities where there is no feasible alternative to their location. The Cape Cod Commission and local Conservation Commissions may require a larger buffer area where necessary to protect sensitive areas or where site conditions such as slopes or soils suggest that a larger buffer area is necessary to prevent any adverse impact to wetlands and associated wildlife habitat. Where a buffer area is already altered such that the required buffer cannot be provided without removal of structures and/or pavement, this requirement may be modified by the Cape Cod Commission and other relevant permitting authorities, provided it makes the following findings: (1) that the proposed alteration will not increase adverse impacts on that specific portion of the buffer area or associated wetland, and (2) that there is no technically demonstrated feasible construction alternative.
The onshore Covell’s Beach route does not pass through any inland wetland areas or their associated 100-foot buffer zones, other than LSCSF and a very small area of dune.
By routing along existing corridors, the Proponent has avoided any direct impacts to inland wetland resource areas. LSCSF is the only onshore wetland resource area crossed, and the crossing occurs in the vicinity of the Covell’s Beach Landfall Site. The proposed route does not pass within the 100-foot buffer zone of any other inland wetland resource.
WET1.3 – Wetlands, Buffers, and Utility Line Installation
Disturbance of wetlands and buffer areas for operation and maintenance of underground and overhead utility lines (electrical, communication, sewer, water, and gas lines) may occur as provided below. Installation of new utility lines through these areas may occur where the Cape Cod Commission finds no feasible alternative to the proposed route for such facilities. In all instances, disturbance of wetland and buffer areas shall be minimized and surface vegetation, topography, and water flow shall be restored substantially to the original condition.
4771.03/Vineyard Wind Connector 5-48 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The Vineyard Wind Connector is presumptively water-dependent: the Massachusetts regulations at 310 CMR 9.12(2)(e), provide that “in the case of a facility generating electricity from wind power (wind turbine facility) or any ancillary facility therefore, for which an EIR is submitted, the Department shall presume such facility to be water dependent if the Secretary has determined that such facility requires direct access to or location in tidal waters.”
As a transmission project designed to connect infrastructure in an offshore Wind Development Area located in federal waters to an interconnection point on shore that is part of the regional electric grid, the Vineyard Wind Connector must necessarily cross flowed tidelands and cannot be located away from those tidelands while achieving the expressed Project purpose.
As described above, by routing along existing onshore corridors, the Proponent has avoided any direct impacts to inland wetland resource areas.
WET1.4 – Stormwater
Stormwater management plans for new development shall preclude direct discharge of untreated stormwater into natural wetlands and water bodies. New stormwater discharges shall be located a minimum of 100 feet from wetlands and water bodies.
There are no wetlands within 100 feet of the proposed substation site, which is the only area where the Project will require stormwater management, and the site is in the mid-Cape area on the sideslope of a glacial moraine with well-drained granular soils. In addition, there are no perennial streams located within 200 feet of the site. Therefore, the Project will not result in any direct discharges of stormwater into wetlands or water bodies. A Stormwater Management Report for the proposed substation site is provided in Attachment H.
5.7 Wildlife and Plant Habitat
The Natural Systems section of the RPP contains the goals and policies applicable to wildlife and plant habitat on the Cape. Project consistency with the applicable goals and MPS related to wildlife and plant habitat is addressed below.
5.7.1 Goal WPH1 – Prevent Loss, Minimize Adverse Impact, and Maintain Diversity
Goal WPH1 is “[t]o prevent loss or degradation of critical wildlife and plant habitat, to minimize the adverse impact of new development on wildlife and plant habitat, and to maintain existing populations and species diversity.” Project consistency with the applicable MPS is discussed below.
4771.03/Vineyard Wind Connector 5-49 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. WPH1.1 – Natural Resources Inventory
Applications for Developments of Regional Impact that propose to alter undeveloped areas shall contain a natural resources inventory. Such inventory shall identify the presence and location of wildlife and plant habitat, including vernal pools, and serve as a guide for the layout of the development. Developments shall be planned to minimize adverse impacts to wildlife and plant habitat. Guidance on preparation of natural resources inventories can be found in Development of Regional Impact Guidelines for Natural Resources Inventory (Plant and Wildlife Habitat Assessment), Technical Bulletin 92-002, as amended.
A Natural Resources Inventory has been prepared for the substation site. Please see Appendix K.
WPH1.2 – Clearing and Grading
Clearing of vegetation and alteration of natural topography shall be minimized, with native vegetation planted as needed to enhance or restore wildlife habitat. Standing specimen trees shall be protected. The Commission may require designation of building envelopes (for structures, driveways, lawns, etc.), where appropriate, to limit removal of vegetation.
The only vegetation clearing proposed for the Project will be on the site of the proposed substation. Of the 6.35-acre leased area, approximately 5.9 acres will be cleared to accommodate the proposed infrastructure. A vegetated buffer at least 50 feet wide will be maintained on the south side of the site; in areas where it will not interfere with the existing utility ROW, a vegetated buffer at least 30 feet wide will also be maintained on the east side of the site. Grading on the substation site will be a cut-and-fill whereby the northern end of the site will be reduced in elevation and the southern portion of the site will be raised, resulting in an even grade.
WPH 1.3 – Wildlife and Plant Habitat
Fragmentation of wildlife and plant habitat shall be minimized by the establishment of greenways and wildlife corridors of sufficient width to protect not only edge species but also species that inhabit the interior forest, as well as by the protection of large unfragmented areas, and the use of open space or cluster development. Wildlife shall be provided with opportunities for passage under or across roads and through developments where such opportunities will maintain the integrity of wildlife corridors. Fencing shall not be constructed so as to interfere with identified wildlife migration corridors.
The proposed onshore duct bank will follow existing roadway layouts, and the proposed substation will be developed adjacent to other developed parcels; as such, the Project will not contribute to habitat fragmentation. The only fencing proposed for the Project will surround the proposed substation equipment to maintain safety and security, and will not interfere with wildlife migration corridors.
4771.03/Vineyard Wind Connector 5-50 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. WPH1.4 – Rare Species
DRIs within critical wildlife and plant habitat areas shall submit the development proposal to the Massachusetts Natural Heritage Program for review and comment. DRIs that would adversely affect habitat of local populations of rare wildlife and plants shall not be permitted. Development may be permitted where the proponent can demonstrate that such development will not adversely affect such habitat. A wildlife and plant habitat management plan may be required as a condition of approval when development or redevelopment is permitted in critical wildlife and plant habitat areas.
Please see Section 4.3.1.
WPH1.5 – Vernal Pools
Where a project site is located adjacent to a vernal pool (as defined herein), development shall be prohibited within a 350-foot undisturbed buffer around these resources. New stormwater discharges shall be located a minimum of 100 feet from vernal pools.
The Project is not located adjacent to a vernal pool, and will have no stormwater discharges within 100 feet of vernal pools; therefore, this MPS does not apply.
WPH1.6 – Invasive Species
Development on sites where a natural resources inventory identifies the presence of invasive plant species shall provide and implement a management and restoration plan detailing the management of, and where possible, the eradication of the invasive species present, and for revegetating the site with native species. A current listing of invasive species can be found on the web at www.massnrc.org/mipag/invasive.htm.
No areas dominated by invasive plant species have been observed along the Project corridor or substation site.
5.8 Open Space Protection and Recreation
The Natural Systems section of the RPP contains the goals and policies applicable to open space and recreation. Project consistency with the applicable goals and MPS related to open space and recreation is addressed below.
5.8.1 Goal OS1 – Open Space and Natural Resources
Goal OS1 is “[t]o preserve and enhance the availability of open space that provides wildlife habitat and recreational opportunities, and protects the region’s natural resources and character.” Project consistency with the applicable MPS is discussed below.
4771.03/Vineyard Wind Connector 5-51 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. OS1.1 – Clustering of Development
Development or redevelopment within Significant Natural Resource Areas, as illustrated on the Cape Cod Significant Natural Resource Area (SNRA) Map, as amended, shall be clustered away from sensitive resources and maintain a continuous corridor to preserve interior wildlife habitat. Where a property straddles the boundary of an area shown on the SNRA map, development shall be clustered outside the boundary.
The proposed onshore duct bank is necessarily a linear feature and will predominantly follow existing paved roadways, and the proposed substation will be developed adjacent to other developed parcels; as such, the Project will not contribute to habitat fragmentation (see Figure 5-4).
OS1.2 – Open Space Connections
Preserved open space within proposed developments shall be designed to be contiguous and interconnecting with adjacent open space…
The Project does not involve the creation or preservation of open space; therefore, this MPS does not apply. Existing land uses will remain unchanged except for the site of the proposed substation, where proposed substation equipment will be contained within a fence line to maintain safety and security.
OS1.3 – Open Space Requirements
All development… that qualifies as a DRI shall provide permanently restricted upland open space in accordance with the proportional calculation described below…
In October of 2018 Vineyard Wind finalized a Host Community Agreement (HCA) with the Town of Barnstable, where the upland cable and substation are proposed to be sited. The HCA requires Vineyard Wind to make annual payments to the Town of at least $1.534 million each year in combined property taxes and Host Community Payments. The pact guarantees a total Host Community Payment of $16 million, plus an additional $60,000 (adjusted for inflation annually) for each year the project is in operation beyond 25 years. The HCA details additional commitments as well, including funding of a new bathhouse and restoration of Covell’s Beach parking lot following construction. Because of the extraordinary nature of this commitment, the Applicant respectfully requests that the mitigation provided through the auspices of the HCA be considered to satisfy this provision.
4771.03/Vineyard Wind Connector 5-52 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. OS1.4 – Sensitive Natural Resources
In the design of developments, significant natural and fragile areas including critical wildlife and plant habitat, significant natural communities, water resources…, wetlands, 100-foot buffers to wetlands, historic, cultural, and archaeological areas, significant scenic roads and views… shall be protected. Development should be located outside of 300-foot buffers to ponds and lakes and 200-foot buffers to rivers to the greatest extent feasible.
The proposed onshore duct bank will predominantly follow existing paved roadways, and the proposed substation will be developed adjacent to other developed parcels; as such, the Project will not contribute to habitat fragmentation or have any permanent impacts to wetlands.
The proposed onshore and offshore export cables will be entirely buried, with the only surface exposure being periodic manhole covers along the duct bank route that will be flush with grade. The Project will not permanently affect any significant scenic roads or views.
The Project is predominantly located along roadways and involves standard inert materials such as concrete, PVC conduit, and solid dielectric cable. The proposed cables will not contain any liquids, oils, or other substances that could leak out of the cables. The proposed substation site is also located within a Wellhead Protection Area, and will be equipped with full containment for any components containing dielectric fluid, including all transformers, reactors, and capacitor banks (see Section 2.4.3).
All necessary precautions, including implementation of construction-period stormwater, erosion, and spill prevention controls, will be taken to ensure there are no impacts to water resources or wetland resource areas.
As described in Section 4.9, the Project is not expected to result in any impacts to historic, cultural, or archaeological resources.
OS1.5 – Residential Cluster
All residential subdivisions of five or more lots and all commercial subdivisions of land…
The Project does not involve a residential or commercial subdivision; therefore, this MPS does not apply.
4771.03/Vineyard Wind Connector 5-53 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. OS1.6 – Sensitive Open Space Resources
Where development is proposed adjacent to land held for conservation and preservation purposes, or adjacent to rural landscapes or lands in active agricultural production, the development shall be configured so as to prevent adverse impacts to these lands and in a manner that maximizes contiguous open space. Additional vegetated buffers may be required where necessary to screen or separate uses.
The site of the proposed substation, which is the only area where the Project will result in any permanent change in land use, is not proposed adjacent to land held for conservation and preservation or adjacent to rural landscapes or lands in active agricultural production.
OS1.7 – Open Space in GIZ/Economic Centers
Notwithstanding Significant Natural Resource Area designation, where development is proposed in Growth Incentive Zones/Economic Centers, the open space requirement shall be reduced to the proportion required for Growth Incentive Zones/Economic Centers where a natural resources inventory demonstrates that there are no wetlands, surface water bodies, vernal pools, estimated rare species habitat, agricultural soils, priority natural communities, critical upland areas, public water supply Wellhead Protection Areas, or other unique or fragile habitat within 100 feet of the site boundary.
As shown on the Regional Land Use Vision Map in Figure 4-12, the proposed substation is proposed within an Industrial and Service Trade Area, and is adjacent to an Economic Center. Portions the proposed route pass through areas mapped as Economic Centers. Since the proposed duct bank will be installed entirely underground, the Project will have no permanent effect on existing land uses or open space, and will not alter the character of the land through which it will pass. The site for the proposed substation is already located within an industrial area, bordered to the north by the Barnstable Switching Station, to the west by the former Cape Cod Times building, to the south by Independence Drive, and to the east by an existing approximately 150- to 200-foot-wide electric transmission corridor with a number of 115 kV overhead lines on H-frame and single pole support structures.
OS1.8 – Open Space Requirements and Parking Garages
… [P]rojects meeting parking requirements under proposed buildings or as a multi-storied parking garage may reduce their open space requirement…
The Project does not involve parking under a building or a parking garage; therefore, this MPS does not apply.
4771.03/Vineyard Wind Connector 5-54 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. OS1.9 – Location of Open Space
Wherever possible, off-site open space provided through MPS OS1.3 is encouraged within or contiguous to Cape Cod Significant Natural Resource Areas or in the areas identified in MPS OS1.4.
OS1.3 specifies that a development area that must be mitigated is “any previously undisturbed upland area.” Since the proposed duct bank will be installed entirely underground, the Project will have no permanent effect on existing land uses or open space, and will not alter the character of the land through which it will pass. The site for the proposed substation is already located within an industrial area, bordered to the north by the Barnstable Switching Station, to the west by the former Cape Cod Times building, to the south by Independence Drive, and to the east by an existing approximately 150- to 200- foot-wide electric transmission corridor with a number of 115 kV overhead lines on H- frame and single pole support structures. Figure 5-4 shows the Project’s Onshore Export Cable Route and substation on a CCC Singificant Naureal Resource Area Map.
OS1.10 – Open Space Credits
As an incentive for the increased protection of sensitive or significant natural resources, and at the discretion of the Commission, the open space requirement may be reduced by 20 percent where…
The open space requirement in OS1.3 specifies that a development area that must be mitigated is “any previously undisturbed upland area.” Since the proposed duct bank will be installed entirely underground, the Project will have no permanent effect on existing land uses or open space, and will not alter the character of the land through which it will pass. The site for the proposed substation is already located within an industrial area, bordered to the north by the Barnstable Switching Station, to the west by the former Cape Cod Times building, to the south by Independence Drive, and to the east by an existing approximately 150- to 200-foot-wide electric transmission corridor with a number of 115 kV overhead lines on H-frame and single pole support structures.
5.9 Transportation
The goals of the transportation section of the RPP are to ensure safety of roads, reduce or offset the expected increase in vehicle trips and dependency on the automobile, to maintain travel times and Level of Service on roads, and to ensure that road construction or reconstruction is consistent with community character. The RPP MPS are designed for developments that will have some permanent effect on traffic. The Project, once constructed, will have no permanent effect on traffic; access and egress for the substation site, utilized only for occasional maintenance, will be through the existing access for the site. Temporary construction-related impacts to transportation will be mitigated through Traffic Management Plans, signage, and the use of police details.
4771.03/Vineyard Wind Connector 5-55 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. 5.10 Waste Management
The issue of waste management in the RPP relates to the challenges Cape Cod faces in managing its solid and hazardous wastes in an environmentally sound manner. Project consistency with the applicable goals and MPS related to wetlands is addressed below.
5.10.1 Goal WM1 – Hazardous Materials and Waste
Goal WM1 is “[t]o protect Cape Cod’s drinking water by prohibiting land use activities involving the handling, storage, and disposal of hazardous materials and wastes that pose a significant threat to groundwater supplies.” Project compliance with applicable MPS is discussed below.
WM1.1 – Hazardous Materials/Waste Restrictions
Development and redevelopment that involves the use, treatment, generation, handling, storage, or disposal of Hazardous Materials and/or Hazardous Wastes… shall not be allowed within Wellhead Protection Areas and Potential Public Water Supply Areas, except as provided in WM1.2 and WM1.3.
Wellhead Protection Areas, as established by the CCC, consist of areas that contribute groundwater to existing public and community water supply wells and are recognized in conjunction with state standards for Zone II Aquifers (as defined in 310 CMR 22.02). Potential Public Water Supply Areas are areas identified by the CCC as potential future well sites and their associated recharge areas that have been identified by towns, water districts, or private water companies.
The Project is predominantly located along roadways and involves standard inert materials such as concrete, PVC conduit, and solid dielectric cable. The proposed cables will not contain any liquids, oils, or other substances that could leak out of the cables.
The substation site is located within a Zone II Wellhead Protection Area and a Potential Public Water Supply Area. The containment system for the substation is described in Section 4.2.2. The design of the containment system goes well above and beyond industry best practices to ensure protection of the groundwater resource.
During construction, nearly all vehicle fueling and all major equipment maintenance will be performed off-site at commercial service stations or a contractor’s yard. A few pieces of large, less mobile equipment (e.g., excavators, paving equipment) will be refueled as necessary on-site. Any such field refueling will not be performed within 100 feet of wetlands waterways, or within 100 feet of known private or community potable wells, or within any Town water supply Zone I area. Refueling procedures are discussed in Section 4.2.3.
4771.03/Vineyard Wind Connector 5-56 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. WM1.2 – Credit for Redevelopment
Redevelopment within Wellhead Protection Areas that involves use, treatment, generation, handling, storage, or disposal of Hazardous Materials and/or Hazardous Wastes may be allowed to exceed the limits in WM1.1 provided that the quantity of hazardous materials is less than the quantity from the prior use and provided adequate documentation of the previous volume is approved by the Commission.
The proposed substation site is located within an industrial area, and is immediately south of the existing Barnstable Switching Station. However, under existing conditions the area leased for the substation itself does not involve the use, treatment, generation, handling, storage, or disposal of Hazardous Materials and/or Hazardous Wastes.
WM1.3 – Credit for Removal of Development
Development and redevelopment within Wellhead Protection Areas that involves the use, treatment, handling, storage, or disposal of Hazardous Materials and/or Hazardous Wastes may be allowed to exceed the quantity limits of hazardous materials in WM1.1 up to, but not exceeding the amount, that the development or redevelopment permanently eliminates at another facility, project, or site within the same Wellhead Protection Area and provided adequate documentation of the volume eliminated is approved by the Commission.
The substation site is located within a Zone II Wellhead Protection Area and a Potential Public Water Supply Area. As described in Section 4.2.2, the substation design will include at least full volume (110%) impervious containment sumps for all equipment containing dielectric fluid (i.e., the main transformers, reactors, capacitor banks for the harmonics filter and any equipment containing oil associated with the synchronous condensers and/or STATCOMs). The Project will also provide full containment under any oil-containing ancillary equipment (i.e., lube oil system) required for the synchronous condensers, which will be installed in an equipment enclosure or building (see Substation Draft Site Plan, Figure 2-7). While sumps for transformers are standard practice, they are not normally used for other lower-volume fluid-filled equipment given the low probability of any leakage. However, the Company has opted to commit to such containment given the sensitive nature of the Cape Cod watershed and based on consultations with local officials and comments at public meetings. In addition, at the Town of Barnstable’s request, Vineyard Wind has committed to adding additional containment volume in consideration of an extreme rain event. Thus, the Company will adjust the 110% containment volume upwards to account for a simultaneous 100-year, 24-hour rainfall event, which on Cape Cod is conservatively established at 9 inches of rain. Also included in the design as additional mitigation is a common drain system that routes each individual containment area after passing through an oil inhibition device to an oil/water separator before draining to the infiltration basin. These measures are well above and beyond industry best practices to ensure protection of the groundwater resource. The Applicant does not propose to eliminate hazardous materials because of the adequacy of its containment system.
4771.03/Vineyard Wind Connector 5-57 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. WM1.4 – Pollution Prevention and Emergency Response Plan
Development and redevelopment in Wellhead Protection Areas and Potential Public Water Supply Areas shall prepare a Pollution Prevention and Emergency Response plan for both the construction phase and normal operations that identifies potential contamination sources, threats of Hazardous Material and Hazardous Waste releases to the environment, describes material storage and handling details, containment and contingency plans for spill response, and documents regular inspection and employee education opportunities.
Emergency response plans will be developed as described in WM1.4.
WM1.5 – Compliance with Massachusetts Hazardous Waste Regulations
Any development or redevelopment that uses, handles, generates, treats, or stores Hazardous Waste shall be in compliance with Massachusetts Hazardous Waste Regulations, 310 CMR 30.0 for the purposes of Cape Cod Commission review by providing the Commission with evidence of the following:
(a) registration with or notification to the Massachusetts Department of Environmental Protection as a generator of Hazardous Waste;
(b) a written plan or protocol to manage the Hazardous Waste prior to disposal;
(c) a signed contract with a registered, licensed company to dispose of the Hazardous Waste.
Vineyard Wind will comply with all applicable laws pertaining to Hazardous Waste. The Company anticipates the substation site may generate wastes that may be characterized as hazardous wastes (primarily waste oils); any such wastes will be removed from the site in compliance with applicable law. The amount of potentially hazardous wastes generated is expected to be small. Currently Vineyard Wind expects that the substation site will be classified as a“Very Small Quantity Generator” (“VSQG”) under 310 C.M.R. § 30.353. To the extent possible,Vineyard Wind will utilize recycling of the waste streams as allowed under 310 C.M.R. § 30.00.
The Company will provide the CCC with its hazardous waste generator ID once it is obtained, at or around the start of operations. It will also provide a plan or protocol to manage Hazardous Waste which is likely to be included as part of its spill prevention control and countermeasures (SPCC) plan, which will also be prepared prior to the initiation of operations. Finally, the Company will provide a copy of its hazardous waste disposal contract prior to the initiation of operations.
4771.03/Vineyard Wind Connector 5-58 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. 5.10.2 Goal WM2 – Solid Waste
Goal WM2 is “[t]o manage solid waste using an integrated waste management system that includes waste reduction, recycling, and composting…” Project compliance with applicable MPS is discussed below.
WM2.1 – Construction Waste
Development and redevelopment projects shall address the disposal of construction waste at both the construction and post-construction phases of development or redevelopment. To do so, a plan shall be provided to demonstrate how the applicant proposes to handle solid wastes, construction and demolition (C&D) wastes, and recyclable materials currently categorized by the Massachusetts Department of Environmental Protection (DEP) as a waste ban material.
The draft CMP provided as Attachment C of the DEIR addresses the handling of solid waste from the Project. Since the Project will involve open trenching through existing roadways, there will be asphalt and possibly concrete waste generated during construction. Asphalt and concrete will be handled separately from soil to allow for recycling at an asphalt batching plant and/or recycling facility. Waste materials generated during installation of the Project will be promptly removed for recycling or proper disposal of at a suitable facility.
Packing crates and wood from equipment shipments will be reused or recycled to the extent practicable, or will be disposed of appropriately.
Post-construction, the Project will not generate any significant solid waste.
WM2.2 – C&D Waste Plan
If C&D waste is to be generated as a part of the proposed development or redevelopment, a plan shall be provided that specifies:
♦ a listing of C&D wastes that will be generated during the development or redevelopment;
♦ the method for separating, storing, transporting, and disposing of gypsum (wall board and sheetrock)
♦ from the remainder of the waste stream; and
♦ the methods that will be used to recycle or dispose of those remaining materials in the C&D waste stream.
4771.03/Vineyard Wind Connector 5-59 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The draft CMP provided as Attachment C of the DEIR addresses the handling of solid waste from the Project. Since the Project will involve open trenching through existing roadways, there will be asphalt and possibly concrete waste generated during construction. Asphalt and concrete will be handled separately from soil to allow for recycling at an asphalt batching plant and/or recycling facility. Waste materials generated during installation of the Project will be promptly removed for recycling or proper disposal of at a suitable facility.
Packing crates and wood from equipment shipments will be reused or recycled to the extent practicable, or will be disposed of appropriately.
WM2.3 – Post-construction Waste
A solid waste and recycling management plan shall be provided that identifies how both solid wastes and recyclable materials will be handled in the post-construction phase of the development…
Post-construction, the Project will not generate any significant solid waste; therefore, this MPS does not apply.
WM2.4 – Food-waste Recycling
A post-construction management plan shall be provided by those developments (primarily supermarkets) generating significant amounts of food wastes…
The Project will not generate food wastes; therefore, this MPS does not apply.
5.11 Energy
The Energy section of the RPP discusses ways to reduce greenhouse gas emissions and control energy costs for Cape residents by (1) reducing the consumption of energy or utilizing more efficient fuels, and (2) reducing the cost of energy from the provider. The MPS are designed for developments that will themselves generate energy demand.
As described in Section 2.5, the purpose of the Vineyard Wind Project is to provide a commercially sustainable wind energy project within its leased area to meet New England’s need for clean energy. The Vineyard Wind lease area is located in in federal waters off Massachusetts, and is part of the federally-designated Wind Energy Area on the Outer Continental Shelf. The Project will deliver up to 800 MW of power to the New England energy grid, will make a substantial contribution to the region’s electrical reliability, will help meet individual state renewable energy requirements, and will offset over 1.6 million tons of CO2 annually (see Section 2.5). Those requirements include the Commonwealth’s mandate that distribution companies jointly and competitively solicit proposals for offshore wind energy generation for an aggregate nameplate capacity of 1,600 MW. The Project will
4771.03/Vineyard Wind Connector 5-60 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. provide significant savings and benefits to electricity customers in Massachusetts, which recent filings at the MA Department of Energy Resources have calculated at approximately $1.4 billion in total net benefits over the life of the contract
The proposed Vineyard Wind Connector would enhance the reliability and diversity of the energy mix on Cape Cod and in the Commonwealth of Massachusetts. This is particularly important given that several base load/cycling plants have already retired or are slated for retirement, including:
♦ Brayton Point Power Plant (Somerset, MA): 1,600 MW, closed on May 31, 2017;
♦ Pilgrim Nuclear Power Plant (Plymouth, MA): 690 MW, to be closed by May 31, 2019;
♦ Vermont Yankee Nuclear Power Plant (Vernon, VT): 620 MW, shut down December 29, 2014;
♦ Montaup Power Plant (Somerset, MA): 174 MW, shut down in 2010; and
♦ Mt. Tom Station (Holyoke, MA): 136 MW, shut down in 2014.
In addition, other plants such as Canal Generating Station (1,200 MW, oil/natural gas-fired, two units commissioned in 1968 and 1976), located in Sandwich, are approaching their normal end of life, making it important for other energy generation alternatives to fill the gap. Along with the plants mentioned above, ISO-NE has identified over 5,000 MW of oil and coal capacity “at risk” for retirement in the coming years.5
Between the decommissioning of nuclear power plants at Pilgrim and Vermont Yankee, and in the 1990s closings of Yankee Rowe (185 MW) and Maine Yankee (900 MW), New England has lost or is about to lose a significant portion of its large “zero carbon” base load plants.
Lastly, Cape Cod is at the outer edge of the regional transmission system. The Cape is essentially supplied by one 345 kV and two 115 kV radial feeds. While recent significant investments in transmission reliability have strengthened the electricity supply to Cape Cod, Vineyard Wind would further improve reliability by feeding power into the center of the Cape transmission system. Connecting a substantial electricity supply to Cape Cod will mitigate future costs for ensuring reliable service to Massachusetts customers.
The Vineyard Wind project will be a major source of zero-carbon electric power. The 800- MW project can supply more than the peak load for all of Cape Cod when running at full capacity. As the offshore wind industry has developed, wind turbines have moved further offshore. When coupled with higher hub heights and longer, more efficient blades, the
4771.03/Vineyard Wind Connector 5-61 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. Vineyard Wind WTGs will take full advantage of a superior wind regime that is found over 14 miles from shore. Accordingly, the Vineyard Wind project is expected to operate at an annual capacity factor in excess of 45%, and the Company’s engineers expect that the Project will be delivering at least some energy from the offshore wind turbine array, located entirely in federal waters, more than 95% of the time. Moreover, summer offshore wind patterns will allow the project to produce substantial power during summer afternoons/early evenings, typical peak power demand periods on the Cape and the Islands.
The Vineyard Wind Connector will also reduce winter electricity price spikes because of its high and stable winter capacity factor. It will enhance energy supply diversity, and as a wind project will not be affected by possible cold weather gas limitations or supply shortages. As such, it will help to promote price stability and energy security.
5.12 Affordable Housing
The Affordable Housing section of the RPP is intended to promote the “provision of fair, decent, safe, affordable housing… that meets the needs of present and future Cape Cod residents.”
The Project does not involve the construction of new housing, and hence the MPS in this section of the RPP do not apply.
5.13 Heritage Preservation/Community Character
The Heritage Preservation and Community Character section of the RPP contains the goals and policies applicable to protecting the historic and cultural features of Cape Cod’s landscape and built environment. Project consistency with the applicable goals and MPS related to heritage preservation and community character is addressed below.
5.13.1 Goal HPCC1 – Historic, Cultural, and Archaeological Resources
Goal HPCC 1 is “[t]o protect and preserve the important historic and cultural features of Cape Cod’s landscape and built environment that are critical components of the region’s heritage and economy.” Project compliance with applicable MPS related to this goal is discussed below.
HPCC1.1 – Historic Structures
An historic structure’s form, massing, and key character-defining features, including the relationship to its site and setting, shall be preserved…
The Project does not involve any alterations to historic structures; therefore, this MPS does not apply.
4771.03/Vineyard Wind Connector 5-62 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. HPCC1.2 – Cultural Landscapes
The distinguishing original features of an historic or cultural landscape shall be preserved. New development adjacent to or within historic or cultural landscapes shall be located to retain the distinctive qualities of such landscapes and shall be designed to maintain the general scale and character-defining features of such landscapes…
As described in Section 4.9, construction and operation of the Project will not affect any historic buildings or structures. Furthermore, since the export cables will be entirely underground or buried beneath the seafloor, they will have no visual impacts and will not alter existing ground-level conditions or land uses. The site of the proposed substation is already located in an industrial area and is immediately south of an existing substation, and therefore is consistent with existing land uses and will not affect the characteristics of the area.
HPCC1.3 – Archaeological Sites
Where development is proposed on or adjacent to known archaeological sites or sites with high archaeological sensitivity as identified by the Massachusetts Historical Commission (MHC) or the Local Historical Commission during the review process, it shall be configured to maintain and/or enhance such resources where possible. A predevelopment investigation of such sites shall be required early in the site planning process to serve as a guide for layout of the development. Archaeological sites determined eligible for listing on the National Register of Historic Places shall be preserved and protected from disturbance.
Please see Section 4.9.
5.13.2 Goal HPCC2 – Community Character/Site and Building Design
Goal HPCC2 is “[t]o encourage redevelopment of existing structures as an alternative to new construction, and to ensure that all development and redevelopment respects the traditions and distinctive character of historic village centers and outlying rural areas…” Project consistency with applicable MPS related to this goal is discussed below.
HPCC2.1 – Strip Development
Creation or extension of strip development shall not be permitted…
The Project does not involve strip development; therefore, this MPS does not apply.
HPCC2.2 – Protection of Existing Roadway Character
New development proposed on local and regional roadways shall be sized such that it can be accommodated without significant changes to the existing character of the roadway.
4771.03/Vineyard Wind Connector 5-63 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The onshore duct bank will largely be constructed along existing roadways; however, the duct bank will be installed entirely underground, and will not result in any permanent alteration to the character of the roadway. The design of the proposed substation site includes at least a 50-foot-wide vegetated buffer between Independence Drive and the substation, which will minimize visual impacts from the roadway.
HPCC2.3 – Avoid Adverse Visual Impacts
New development shall be sited and designed to avoid adverse visual impacts to scenic resources. Visual Impact Assessments (VIA) shall be required for DRI review of any WECF in the Cape Cod Ocean Planning Area as defined in the Cape Cod Ocean Management Plan dated October 2011 and shall be conducted in accordance with Technical Bulletin 12- 001, as amended. VIA may be required as part of DRI review of other Development based upon staff recommendation and vote of the Regulatory Committee that a VIA is necessary to evaluate impacts from the development. Development proposed adjacent to scenic roads or vistas shall preserve distinctive features of the scenic resource including tree canopy, wooded road edges, stone walls, winding road character, and scenic views. Development adjacent to or within scenic vistas shall be clustered and designed to limit the visibility of the new development.
Since the export cables will be entirely underground or buried beneath the seafloor, they will have no visual impacts and will not alter existing ground-level conditions or land uses. The site of the proposed substation is already located in an industrial area and is immediately south of an existing substation, and therefore is consistent with existing land uses and will not affect the visual characteristics of the area. Vineyard Wind’s Wind Development Area is located in federal waters more than 30 miles south of Cape Cod, and therefore is not within the Cape Cod Ocean Planning Area as defined in the Cape Cod Ocean Management Plan.
HPCC2.4 through HPCC2.7
These MPS apply to building design standards. The only structure proposed as part of the Project is an approximately 1,200-square-foot equipment enclosure within the proposed substation; therefore, these MPS do not apply.
HPCC2.8 – Parking to the Side or Rear of Buildings
The building and layout of all parking lots shall follow good design practices and reinforce regional development patterns. Parking for all development shall be located to the rear or the side of a building or commercial complex unless such location would have an adverse or detrimental impact on environmental or visual features on the site. In such cases, alternative means of minimizing environmental or visual impacts of the proposed parking shall be required.
4771.03/Vineyard Wind Connector 5-64 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. The Project does not involve parking except for a small lot immediately adjacent to the proposed substation where it will be located between the substation and the existing building west of the leased area. The substation design includes at least a 50-foot-wide vegetated buffer on the south side of the site and, in areas where it will not interfere with the existing utility ROW, at least a 30-foot-wide vegetated buffer along the east side of the site. These buffers will minimize the visibility of the proposed substation.
HPCC2.9 – Landscaping Improvements for Redevelopment
Redevelopment shall significantly improve buffers between parking areas and the street, as well as interior parking-lot landscaping, and shall provide façade improvements and frontage buildings, as necessary and if appropriate, to improve the visual character of the site.
The substation design includes at least a 50-foot-wide vegetated buffer on the south side of the site and, in areas where it will not interfere with the existing utility ROW, at least a 30- foot-wide vegetated buffer along the east side of the site. These buffers will minimize the visibility of the proposed substation.
HPCC2.10 – Landscape Plan Requirements
All development shall provide landscaping that integrates buildings with their environment, enhances architectural features, fosters sustainable practices, clearly divides parking lots into smaller areas, includes tree planting, and provides amenities for pedestrians. All development shall implement a landscape plan that addresses the functional aspects of landscaping, such as drainage and innovative stormwater technologies, erosion prevention, screening and buffering, provision for shade, and energy conservation. When vegetative buffers are necessary to prevent adverse visual impacts from new development, existing vegetation shall be retained and unaltered in the buffer area. A maintenance agreement shall be provided by all development for a minimum of three growing seasons to insure vegetation is properly established.
The substation design includes at least a 50-foot-wide vegetated buffer on the south side of the site, which is currently wooded. In addition, in areas where it will not interfere with the existing utility ROW, a vegetated buffer at least 30 feet wide will be maintained on the east side of the site. Stormwater management on the substation site is discussed in the Stormwater Management Report provided as Attachment H.
HPCC2.11 – Exterior Lighting
Site lighting and exterior building lights in all development shall meet the following standards. This MPS shall not apply to aviation warning or marking lights as may be required by the Federal Aviation Administration.
4771.03/Vineyard Wind Connector 5-65 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. ♦ Employ “show-box” type or decorative fixtures, consistent with the architectural theme of the development and which are fully shielded.
♦ Use a mounting configuration that creates a total cutoff of all light at less than ninety (90) degrees from vertical (flood, area, and up-lighting are prohibited).
♦ Provide total cutoff of all light at the property lines of the parcel to be developed.
♦ Meet a maximum initial horizontal foot-candle level of not more than 8.0 foot- candles, as measured directly below the luminaire(s) at grade.
During construction, installation of offshore export cables will likely extend around-the- clock, but during that operation lighting will be limited to lights aboard the installation vessels. HDD operations at the Landfall Site may also extend beyond normal work hours, and the drill pit locations will need to be illuminated. The contractor will illuminate the work area to comply with Occupational Safety and Health Administration (OSHA) standards, but will also take care to minimize the amount of construction lighting that extends outside the immediate work zone. Any lighting at the Landfall Site will be shielded and directed away from nearby homes. Small work lights will be positioned in critical areas for machine operators, and will be kept low and shielded to avoid and minimize any disturbance to neighbors. These small work lights may be powered by a sound-attenuated generator.
Outdoor lighting is planned at the proposed substation. Light fixtures are typically holophane-type fixtures equipped with light shields to prevent light from encroaching into nearby residential areas. Light shields may be rotated within fixtures to the most effective position to keep light overflow from leaving the substation. The ideal situation would be to have light overcast outside the substation fence to be as close to 0 foot candles as possible. The design will work to comply with night sky lighting standards tothe maximum extent practicable. There are usually a few lights illuminated for security reasons on dusk–to-dawn sensors and perhaps a few on motion-sensing switches, depending on the application that is needed for the site. The majority of lights will be switched on for emergency situations only, and would not be used on a regular basis. The Proponent will work closely with the Town of Barnstable to ensure the lighting scheme is in compliance with the Town’s requirements.
HPCC2.12 – Signage
The installation of billboards, off-site advertising (except approved directional signs), and internally lit or flashing signs shall not be permitted…
The Project does not involve billboards, off-site advertising, or internally lit or flashing signs; therefore, this MPS does not apply.
4771.03/Vineyard Wind Connector 5-66 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc. HPCC2.13 – Underground Utilities
All utilities for development including cable shall be placed underground except where the presence of natural features such as wetlands or archaeological resources prevent such placement.
The Project consists of buried offshore and onshore export cable, with the only above- ground elements related to the proposed substation.
HPCC2.14 – Roadway Appurtenances
Ornamental signals and mast arms shall be required when the town and the Commission deem it appropriate. Crosswalks shall be constructed of a different texture. In historic areas, the design of roadway appurtenances shall be consistent with historic district styles.
The Project does not involve roadway appurtenances; therefore, this MPS does not apply.
5.14 Conclusion
As described herein, the proposed Project is consistent with the applicable goals and MPS contained within the Cape Cod RPP.
4771.03/Vineyard Wind Connector 5-67 Consistency with Regional Policy Plan DRI Application Narrative Epsilon Associates, Inc.